Metrics-related testing of an operational support system (OSS) of an incumbent provider for compliance with a regulatory scheme

ABSTRACT

Methods are provided for metrics-related testing of one or more operational support systems (OSSs) of an incumbent provider for compliance with a regulatory scheme, the method performed by an independent testing entity attempting to emulate a competitive provider that would access the OSSs in attempting to compete with the incumbent provider in an open competitive market. Each method includes an active testing phase in which one or more OSSs are tested. Performance of the incumbent provider during active testing is evaluated according to predetermined evaluation criteria. Test results are generated according to the evaluation and a final report is issued. The final report includes the test results and provides a sufficient basis for a regulatory entity administering the regulatory scheme to determine compliance of the incumbent provider with the regulatory scheme.

RELATED APPLICATIONS

This application claims priority under 35 U.S.C. §119(e) to U.S.Provisional Application No. 60/214,927, filed Jun. 26, 2000.

TECHNICAL FIELD OF THE INVENTION

This invention relates generally to testing methodologies and moreparticularly to metrics-related testing of an Operational Support System(OSS) of an incumbent provider for compliance with a regulatory scheme.

BACKGROUND OF THE INVENTION

In the United States, a regulatory entity of a state or otherjurisdiction may be tasked with considering whether, and to what extent,an ILEC is in compliance with the requirements of Section 271 of TheTelecommunications Act of 1996 (“the 1996 Act”). The 1996 Act, togetherwith associated Federal Communications Commission (FCC) interpretations,generally require an ILEC seeking to enter the market for long distancetelecommunications services to: (1) provide the relevant CLEC communitywith non-discriminatory access to the ILEC's OSSs, subject to suitableterms and conditions; (2) provide documentation and support necessaryfor CLECs to use these OSSs; and (3) demonstrate that these OSSs areoperationally ready and provide an acceptable level of performance tothe CLEC community. Compliance with these requirements should, forexample, allow CLECs to obtain pre-ordering information, fulfill ordersfor resale services and unbundled network elements (UNEs), manageproblems, and obtain billing information in a manner that isnon-discriminatory as compared to the ILEC's own retail operations.

The regulatory entity may retain an independent testing entity to testand evaluate the readiness of the ILEC's OSS interfaces, documentation,and processes to support local market entry by CLECs. Based on itstesting activities, the testing entity may generate a report documentingthe manner in which its testing activities were conducted, results ofthe testing activities, and its evaluations based on the results. Theaudience for the report will generally fall into two main categories:(1) readers who will use the report in connection with the regulatoryprocess, and (2) any other interested parties who may have some stake inthe matter and wish to have visibility into the testing activities,results, and evaluations (e.g., the ILEC being evaluated, the CLECs, andother ILECs). While many of the above parties may have some interest inthe outcome of the testing activities, typically only the regulatoryentity and the ILEC are parties to the contract with the testing entity.

SUMMARY OF THE INVENTION

According to the present invention, problems and disadvantagesassociated with testing OSSs of an incumbent provider may be reduced oreliminated.

In one embodiment of the present invention, a method for testing one ormore OSSs of an incumbent provider for compliance with a regulatoryscheme is performed by an independent testing entity attempting toemulate a competitive provider that would access the OSSs in attemptingto compete with the incumbent provider in an open competitive market.The method includes conducting active testing of the OSSs with respectto one or more variables and evaluating performance of the incumbentprovider during active testing with respect to the one or more variablesaccording to predetermined evaluation criteria comprising one or moreperformance metrics. Evaluation of incumbent provider performanceincludes, for performance metrics requiring the incumbent provider tomeet a particular performance standard, using a one-sample t-test forcontinuous variable performance metrics and a binomial test for discretevariable performance metrics. For performance metrics requiring paritybetween incumbent provider performance for operations of the incumbentprovider associated with its interaction with competitive providers andincumbent provider performance for its internal operations, a two-samplet-test is used for continuous variable performance metrics and ahyper-geometric test is used for discrete variable performance metrics.The method further includes generating test results according to theevaluation and issuing a final report comprising the test results andproviding a sufficient basis for a regulatory entity administering theregulatory scheme to determine compliance of the incumbent provider withthe regulatory scheme.

In another embodiment of the present invention, a method for testing oneor more OSSs of an incumbent provider for compliance with a regulatoryscheme is performed by an independent testing entity attempting toemulate a competitive provider that would access the OSSs in attemptingto compete with the incumbent provider in an open competitive market.The testing is associated with metrics capture, tracking, and reportingactivities of the incumbent provider with respect to a particularoperational domain. For testing of an OSS, the method includes within adata integrity testing component during active testing, to determinewhether filtered data the incumbent provider uses to calculate valuesfor each of one or more metrics is accurately derived from raw data theincumbent provider collects in connection with transactions associatedwith the OSS: (a) identifying one or more fields in the filtered datathat the incumbent provider uses in calculating values for the metric;(b) identifying a random sample of transactions associated with the OSS;(c) obtaining from the incumbent provider copies of records associatedwith the identified transactions, the records containing raw data forthese transactions from which filtered data for these transactions inthe identified fields was derived; and (d) for each identified field,determining whether the filtered data for the identified transactions inthe identified field is consistent with the raw data for the identifiedtransactions contained in the associated records. The method furtherincludes within a metrics replication testing component during activetesting, for each of one or more metrics for which the incumbentprovider has calculated values: (a) obtaining from the incumbentprovider a description of the metric, filtered data on which theincumbent provider based its calculation of values for the metric, andan algorithm according to which the incumbent provider made itscalculation of values for the metric, the filtered data being associatedwith a specified time period, the filtered data being derived from rawdata the incumbent provider collected in connection with transactionsassociated with the OSS; (b) re-calculating values for the metricaccording to the description, data, and algorithm obtained from theincumbent provider; and (c) determining whether the re-calculated valuesare consistent with the values calculated by the incumbent provider. Themethod further includes evaluating performance of the incumbent providerduring active testing according to predetermined evaluation criteria,generating test results according to the evaluation, and issuing a finalreport comprising the test results and providing a sufficient basis fora regulatory entity administering the regulatory scheme to determinecompliance of the incumbent provider with the regulatory scheme.

In another embodiment of the present invention, a method for testing oneor more OSSs of an incumbent provider for compliance with a regulatoryscheme is performed by an independent testing entity attempting toemulate a competitive provider that would access the OSSs in attemptingto compete with the incumbent provider in an open competitive market.The testing is associated with performance metrics capture, tracking,and reporting activities of the incumbent provider across a plurality ofoperational domains. The method includes conducting a metrics datacollection and storage test during active testing to evaluate incumbentprovider policies and practices for collecting and storing data used forcalculating performance metric values, both for internal operations ofthe incumbent provider and for operations of the incumbent providerassociated with its interaction with competitive providers. The methodalso includes conducting a metrics definition documentation andimplementation test during active testing to evaluate incumbent providerpolicies and practices for documenting and implementing performancemetric definitions, implementation of performance metrics definitionscomprising applying exclusions and business rules in calculatingperformance metric values based on raw data. The method also includesconducting a metrics change management test during active testing toevaluate incumbent provider policies and practices for developing,implementing, monitoring, and reporting changes concerning performancemetrics, conducting a metrics data integrity test during active testingto evaluate incumbent provider policies and practices for processingdata necessary to calculate performance metric values, and conducting ametrics calculation and reporting test during active testing to evaluatepolicies and practices of the incumbent provider for calculatingperformance metric values. The metrics calculation and reporting testincludes (a) accessing calculated performance metric values foroperations of the incumbent provider associated with its interactionwith competitive providers, these values having been calculated by theincumbent provider and thereafter reported to the regulatory entity; (b)re-calculating the accessed performance metric values; (c) comparing there-calculated values with the accessed values to identify anydiscrepancies; (d) attempting to reconcile any identified discrepanciesbetween the re-calculated values and the accessed values; and (e)determining whether the incumbent provider calculated the accessedvalues consistent with documented instructions for doing so. The methodalso includes conducting a statistical evaluation of transactions testduring active testing to evaluate metrics-related service performance ofthe incumbent provider according to statistical techniques. This testincludes accessing test performance metric values calculated based oninteraction between the incumbent provider and the testing entity,accessing benchmark performance metric values calculated based oninteraction between the incumbent provider and one or more competitiveproviders, and comparing the test performance metric values with thebenchmark performance metric values according to statistical techniquesto determine whether and to what extent parity exists between thecompared values. The method further includes evaluating performance ofthe incumbent provider during active testing according to predeterminedevaluation criteria, generating test results according to theevaluation, and issuing a final report comprising the test results andproviding a sufficient basis for a regulatory entity administrating theregulatory scheme to determine a net impact of identifiedmetrics-related issues on the ability of competitive providers tocompete with the incumbent provider in an open competitive market.

BRIEF DESCRIPTION OF THE DRAWINGS

To provide a more complete understanding of the present invention andfeatures and advantages thereof, the following description refers to theaccompanying drawings, in which:

FIG. 1 illustrates an example system for testing one or more OSSs of anILEC;

FIG. 2 illustrates an example test life cycle;

FIG. 3 illustrates an example entrance review process;

FIG. 4 illustrates an example data request process;

FIG. 5 illustrates an example interview process;

FIGS. 6A and 6B illustrate example exceptions processes;

FIGS. 7A and 7B illustrates an example final report preparation process;

FIG. 8 illustrates an example system for pre-order, order, andprovisioning testing;

FIG. 9 illustrates an example interface certification test process;

FIG. 10 illustrates an example order template review process;

FIGS. 11A and 11B illustrates example processes to be conducted beforean order is submitted and in connection with order submission,respectively;

FIG. 12 illustrates an example transactional process associated withpre-ordering, ordering, and provisioning testing;

FIG. 13 illustrates an example coordinated cutover process;

FIG. 14 illustrates an example system for maintenance and repairtesting;

FIG. 15 illustrates an example data flow associated with maintenance andrepair testing;

FIG. 16 illustrates example relationships between components that may beused in connection with billing testing; and

FIG. 17 illustrates an example cross-domain testing process.

DESCRIPTION OF EXAMPLE EMBODIMENTS

FIG. 1 illustrates an example system 10 for testing one or more OSSs 12of an ILEC 14. In one embodiment, testing is performed to allow aregulatory entity to consider whether and to what extent ILEC 14provides a relevant community of CLECs 16 with non-discriminatory accessto, use of, and support in connection with OSSs 12 when compared withthe ILEC's own retail operations. Although the present invention isdescribed primarily in the context of United States operations, in whichthe relevant regulatory framework may include the 1996 Act and aregulatory entity may be, for example, a State Public Service Commission(SPSC), those skilled in the art will appreciate that the presentinvention encompasses any suitable regulatory framework, regulatoryentity, or jurisdiction in the United States or elsewhere. In addition,while “ILEC,” “CLEC,” and other terms principally associated with UnitedStates operations are used for purposes of explanation, those skilled inthe art will appreciate that the present inventions encompasses anysuitable incumbent carriers, competitive carriers, and any associatedterminology according to the jurisdiction in which system 10 isimplemented. Moreover, while testing may be described in some instancesas involving particular service types, circuit types, line types,equipment types, bill types, or the like, those skilled in the art willappreciate that the present invention is not limited to suchparticularities and is meant to be limited only as set forth in theappended claims.

In one embodiment, an independent testing entity is responsible fordefining and performing testing activities associated with system 10. Toperform the testing activities, the testing entity establishes one ormore appropriate pseudo-CLECs 18, each of which supports at least someof the systems, processes, personnel, or other resources that a realCLEC 16 would support, such that from the ILEC's perspective pseudo-CLEC18 substantially resembles (to the extent possible) a real CLEC 16 inthe context of a resource being tested. Although it may not be possible,practicable, or even desirable for pseudo-CLEC 18 to emulate a real CLEC16 in each aspect of operation, the ability of the regulatory entity tofairly evaluate ILEC 14 will usually improve with the accuracy withwhich the pseudo-CLEC 18 is able to successfully duplicate experiencesthat a real CLEC 16 would face in interacting with the ILEC's OSSs 12.As such, efforts should be made to establish a pseudo-CLEC 18 that isrepresentative of one or more real CLECs 16, at least in the aspectsthat relate to the criteria on which ILEC 14 will be evaluated. Whereappropriate, the terms testing entity, testing personnel, andpseudo-CLEC 18 may be used interchangeably. Also where appropriate,reference to ILEC 14 or CLEC 16 is meant to encompass one or moreassociated systems, processes, personnel, or other resources.

CLECs 16 and the pseudo-CLEC 18 may interact with the ILEC's OSSs 12using one or more intervening OSS access systems 20, which collectivelyprovide a gateway for OSS processing and an interface to “downstream”support systems. An OSS access system 20 may be associated with one ormore OSSs 12, according to particular needs. OSS access systems 20 maybe coupled to CLECs 16 and pseudo-CLEC 18 (on the CLEC side) and to OSSs12 (on the ILEC side) using links 22 and links 24, respectively. Eachlink 22, 24 may include at least a portion of one or more local areanetworks (LANs), metropolitan area networks (MANs), wide area networks(WANs), a global computer network such as the Internet, or any otherappropriate wired, optical, or wireless links. CLECs 16 and pseudo-CLEC18 may also access one or more OSSs 12 directly without using OSS accesssystems 20, depending on the nature of this access and the particularimplementation. Components of OSSs 12, OSS access systems 20, CLECs 16,and pseudo-CLEC 18 may operate on one or more computer systems at one ormore locations, may access data storage at one or more suitablelocations internal or external to system 10, and may share one or morecomputing resources as appropriate. Where components rely in part oncomputer systems, those computer systems may operate autonomously orsubject to input from one or more users according to particular needsand implementations.

As described above, one of the objectives of the testing activities isto “live” the real CLEC experience. However, it may be difficult or evenimpossible for all testing activities to be truly blind to ILEC 14. Forexample, test transactions may arrive at ILEC 14 on dedicated circuitswhich ILEC 14 knows are associated with pseudo-CLEC 18. Furthermore,ILEC 14 will typically assign to each CLEC 16 (as well as pseudo-CLEC18) a unique set of identifiers that must be included in alltransactions submitted to ILEC 14. To partially offset this lack ofblindness, the testing entity preferably implements procedures to helpensure that pseudo-CLEC 18 will not receive any treatment from ILEC 14that is significantly different from that received by real CLECs 16. Forexample, the testing entity might require that all documentationreceived from ILEC 14 be generally available to all CLECs 16, theregulatory entity may monitor telephone calls, meetings, and othercommunications between pseudo-CLEC 18 and ILEC 14, CLECs 16 may beinvited to monitor some or all such communications, pseudo-CLEC 18 mayreport problems using the same ILEC help desk available to CLECs 16, andthe testing entity may make concurrent observations of service qualitydelivered to real CLECs 16 during the course of its testing activitiesand compare its observations to the quality of the service pseudo-CLEC18 receives. These techniques are merely examples; any suitabletechniques may be used according to particular needs.

The general scope of the testing activities may be documented in advancein an MTP, which the testing entity creates based on its understandingof the ILEC's products, industry trends, input from the regulatoryentity, ILEC 14, and CLECs 16, and any other suitable information. As anexample, the testing entity may consider actual ILEC and CLEC businessplans and projections in developing the MTP. To determine the scope ofits testing activities, all stages of the CLEC-LEC relationship arepreferably considered, including establishing the relationship,performing daily operations, and maintaining the relationship. To betterorganize and facilitate the testing activities, the MTP may be dividedinto a number of testing domains which each generally correspond to onebroad aspect of a customer's relationship with its LEC. In oneembodiment, these testing domains may include, for example only and notby way of limitation, a Pre-Ordering, Ordering, and Provisioning (POP)Domain, a Maintenance and Repair (M&R) Domain, a Billing Domain, and aRelationship Management and Infrastructure (RMI) Domain. In each domain,the testing entity devises and implements testing activities to evaluateILEC performance. Although particular domains are described for purposesof illustration, those skilled in the art will readily appreciate thatthe present invention is meant to encompass any suitable domainsaccording to particular needs. Based on its testing activities, thetesting entity may generate one or more reports documenting the mannerin which testing activities were conducted, results of those testingactivities, and evaluations of the ILEC 14 based on those results.

The testing activities, which are preferably representative of all CLECs16 within the CLEC community, may be broader than activities likely tobe experienced by any single CLEC 16. However, the testing activitiesare not necessarily intended to be exhaustive, because it is generallyneither feasible nor desirable to test all the possible combinations ofall features and functions across all offered products. In some cases,it might not be practicable to simulate some order types, problems, orprocesses in a test situation. Examples might include orders with verylong interval periods, large volumes of test transactions which wouldexceed the capacity of the ILEC's help desk, or complex andtime-consuming network design reviews. In such cases, the testing entitywill preferably attempt alternative test procedures, such as conductingstructured interviews with ILEC and CLEC personnel, inspecting liveorders in process, reviewing historical performance or operationalreports, and any other appropriate procedures to capture the ILEC'sperformance with respect to the activities in question. It will alsogenerally not be practicable to execute certain live tests that mightunduly disrupt service to ILEC or CLEC customers. As a result, ILECperformance for such tests should preferably be evaluated using othermore suitable techniques. The reports for each domain tested willpreferably identify the tests that were executed using live transactionsand those that were executed using other techniques.

In one embodiment, in order to accomplish the testing activities, ILEC14 provisions a “test bed” of accounts suitable to represent a marketshare of ILEC or other CLEC accounts that might be lost to thepseudo-CLEC 18 within an open competitive environment. The notion of atest bed is a logical concept, in that test accounts are actuallycreated in the ILEC's central offices (COs) and its associatedproduction systems rather than in a separate, isolated test environment.The testing entity may define the test bed alone or based on input fromother parties such as the regulatory entity, ILEC 14, CLECs 16, otherILECs 14, or any other suitable parties. If ILEC 14 represents that ascarcity of resources exists in its COs and associated productionsystems, pseudo-CLEC 18 may be forced to use the same test accounts inconnection with multiple test scenarios. For example, the same testaccount might need to be used to test one or more migration scenarios,one or more feature change scenarios, and one or more disconnectscenarios. Dependencies between scenarios may create scheduling problemsfor the testing entity and thus lengthen the testing period, since thetesting entity might need to go through the entire pre-order, order, andprovisioning cycle several times for a single test account.

In formulating an approach to testing, the testing entity may solicitinput from both the regulatory entity and CLECs 16 since it is importantfor the testing entity to appreciate the types of activities that haveeither previously presented problems for CLECs 16 attempting to enterthe market for local telecommunications services, or are otherwise ofgreatest concern to the regulatory entity and/or CLECs 16. The testingentity preferably combines such input with its own experience indeveloping its testing approach.

In one embodiment, two primary types of tests are identified: (1)transaction-driven tests, and (2) operational tests. Transaction-driventesting generally involves initiating transactions, tracking transactionprogress, and analyzing results regarding completed transactions toevaluate a system or process under test. This may require defining thedata sources, system components, and transaction volumes to be used inconnection with a transaction-driven test. In one embodiment, thetransactions to be used in each transaction-driven test are derived fromhigher level sets of one or more transactions referred to as test cases,which in turn have been developed from base test scenarios. Thesescenarios are described more fully below.

In one embodiment, for transaction-driven testing, pseudo-CLEC 18generates and submits pre-order and order transactions to ILEC 14 usingone or more of the ILEC's electronic interfaces—much like a real CLEC 16would do. Transaction-driven testing may be used extensively in the POP,M&R, and Billing domains as described more fully below. To executetransaction-driven tests, the testing entity may assume the role of aCLEC “Operations” group, possibly including performing such tasks asunderstanding applicable business rules, submitting and trackingpre-order and order transactions, logging trouble tickets, andevaluating ILEC-to-CLEC (“carrier-to-carrier”) bills. The testing entitymight also (typically at the same time) assume the role of a CLEC“Information Technology” group, possibly including the establishment ofelectronic bonding with ILEC 14, translating between business and otherrule formats, and resolving any problems associated with pre-order andorder processing. These are merely examples, the testing entity mayassume any suitable role or roles typically associated with a CLEC 14 inconnection with its transaction-driven testing of ILEC 14.

In one embodiment, for example and without limitation, ILEC 14 may offerCLECs 16 access to its OSSs 12 through both an electronic datainterchange (EDI) interface and a web-based or other appropriategraphical user interface (GUI). The testing entity will preferably testall interface types for all appropriate transactions. However, becausean EDI or other substantially automated interface is likely to be moreheavily used than a GUI or other user-oriented interface within acompetitive marketplace, testing of the substantially automatedinterfaces may be emphasized if appropriate. As an example, manytransaction-driven tests in the POP and Billing domains may primarilyuse an EDI interface created according to publicly available ILECspecifications, although a GUI may also be used for selected POP andBilling transactions. In contrast, all M&R trouble tickets may need tobe submitted using a GUI since application-to-application electronicbonding with ILEC 14 might not be available for M&R domain activities.In one embodiment, as described more fully below with respect to the POPDomain, the testing entity establishes a transaction engine to supportits transaction-driven testing efforts. In general, the testing enginesimulates real CLEC behavior by generating and submitting testtransactions to the ILEC's OSSs 12; records the success or failure ofeach transaction; records response times, intervals, or other compliancemeasures; and generates corresponding reports. The testing engine mayperform only a subset of these tasks if appropriate.

Test scenarios are developed to model the way CLECs 16 interact withILEC 14 in satisfying the needs of their customers, providing acontextual basis for testing by defining the transactions, products andservices, volumes, data elements, or other variables to be consideredduring testing. Scenarios provide a way to bridge across test domains,preferably facilitating point-specific, end-to-end, or bothpoint-specific and end-to-end testing of various systems and processes.Some scenarios might be specific to one particular domain, while othersmight span multiple domains. In one embodiment, a key principle indefining these test scenarios is to emulate real-world coverage, mix,and types of transactions while balancing the requirement for practicaland reasonably executable transactions that would not unduly disruptnormal ILEC production or negatively impact service to ILEC customers.The test scenarios will preferably provide a breadth and depth ofcoverage of products and services to be tested, encompassing theprocurement of resale services and UNEs from ILEC 14, querying ofcustomer-specific and ILEC-specific information from the ILEC's OSSs 12,and identifying and resolving any problems that arise in connection withthese activities. In general, each test scenario describes a range ofinteractions between a CLEC 16 and ILEC 14, and may be used to createone or more specific test cases, each of which may in turn be used tocreate one or more specific test transactions. Test scenarios may beadjusted through introduction of errors, changes to orders, or the liketo provide a variety of possible CLEC-ILEC interactions. The testingentity preferably uses a relatively large number of test scenarios instructuring transaction testing of OSSs 12 and related systems andprocesses. Example test scenarios may include, in any suitablecombination and without limitation, those set forth below in Appendix A.

Testing activities will preferably evaluate the ability of ILEC 14 toscale to handle increased CLEC transaction volumes at estimated futurelevels. As discussed above, the overall goal of the testing activitiesis to evaluate the systems, processes, and other operational elementsassociated with the ILEC's support of a competitive market for localtelecommunications services. The purpose of volume testing is toevaluate the ILEC's availability to process representative futuretransaction volumes to support the entry of CLECs 16 into the localmarket. Volume tests are preferably performed at both peak and normalvolumes. In addition, stress tests are preferably performed to testoverall system capacity as to selected transactions and to identitypotential “choke points.” The scope of these volume tests are definedwithin each domain section.

Test volumes may be assigned to particular test cases based oncomplexity, expected real world production, and other appropriatefactors, and may be developed through a synthesis of informationobtained from ILEC 14 and various CLECs 16. This information ispreferably solicited independently by the testing entity. Items suitablefor review in connection with determination of test volumes may includehistoric and forecasted ILEC service demand, historic and forecastedCLEC service demand, historic and forecasted CLEC usage of the ILEC'sOSSs 12 (which might include transactions types and volumes), marketstudies, and any other appropriate information. Although more complextest scenarios may be expected to occur less frequently, test casegeneration should preferably ensure that such test scenarios arerepresented to obtain adequate coverage.

In one embodiment, actual ILEC volume data may be used as the basis fordeveloping normal, peak, and stress volumes for each appropriate testcase. Normal daily volumes may be calculated, for example, based on anestimate of market share captured by CLECs 16 during a selected timeperiod and an expected run rate. For example, the testing entity mayestimate that in a certain month, CLECs 16 gained lineshare at a certainrate, resulting in a certain number of lines CLECs 16 would be expectedto gain during a longer (e.g., three-month) period containing thatmonth. A normal volume test may then simulate a corresponding (thoughpossibly not equal) number of transactions for the ILEC's OSSs 12 toprocess during a testing period of the same (e.g., three-month) length.Other assumptions used in the calculation may include, for example, thenumber of orders per net line added, the number of one or more types(e.g., change/disconnect/move) orders per net line added, the percentageof orders from jurisdictions other than the home or primary jurisdictionof ILEC 14, or any other assumptions. In a particular embodiment, peakvolumes are based on a suitable multiplier of normal volumes, whilestress volumes are based on a suitable multiplier of normal and/or peakvolumes.

Volumes by service and/or order type may be developed using the ILEC'sforecast of competitive lines, viewed by service and order type. Thetesting entity may determine a proportion for each service and ordertype based on forecasted net adds during a selected time period, thenextend or contract the normal daily volume by that proportion to yieldthe daily volume by service and order type. The daily volumes for ordersupplements, order changes/disconnects/moves, and other detailed orderinformation may be calculated by applying historical factors to dailyvolumes by service and order type. Pre-order daily volumes may bederived from historical ILEC actuals during a selected time period ofpre-order type as a percent of order volume. Daily volumes by serviceand order type may be extended or contracted by an appropriate factorbased on that percentage to determine pre-order daily volumes. Orderconfirmation daily volumes may be derived analogously. Gross, initial,and subsequent trouble report rates may be derived from historical ILECactuals, applied to the anticipated embedded base in some selected timeperiod. These are merely examples; test volumes may be developed in anysuitable manner.

In contrast to transaction-driven tests, operational tests focus on theformat, structure, and content of the ILEC's business processes underreview. Operational tests are used to assess the ILEC's day-to-dayoperations and operational management practices, including such thingsas policy development, procedural development, and procedural changemanagement. Operational tests evaluate the ILEC's processes to determinewhether these processes appear to function correctly and in accordancewith documentation and expectations. Operational tests also preferablyevaluate any appropriate ILEC management practices and operatingprocedures, comparing these results to legal, statutory, and otherrequirements.

CLEC live test cases, involving one or more real CLECs 16, may providean alternative test approach for transactions that are not practicableto provide in the test environment, due to certain limitations such asthose described above. Moreover, CLEC live test cases may provide thetesting entity with a different perspective on actual CLEC production.CLEC live production may be monitored during the test period to assessthe service levels experienced by real CLECs 16. In some cases,information may also be gathered from historical CLEC transactions forsystems and processes that have been sufficiently stable for asufficient length of time.

FIG. 2 illustrates an example test life cycle 26 incorporating the majormilestones (filled diamonds) and interim milestones (unfilled diamonds)that, in one embodiment, generally apply to each test described below.Pre-test activities 28 a may include completing background datacollection, completing preliminary development of testing systems, tool,and interfaces, satisfying any remaining entrance criteria, andconducting an appropriate test entrance review process.

An example test entrance review process is illustrated in FIG. 3. Theentrance review process may include a peer review aspect. Peer reviewsare internal project reviews conducted at one or more appropriate timesduring the life of a test. Peer reviews may be desirable in connectionwith entrance review (being required in one embodiment), during thecourse of a test (being optional in one embodiment), or in connectionwith an exit review (being required in one embodiment). An entrancereview is preferably required prior to initiation of the active testingphase of a test. The purpose of this review is to ensure that allentrance criteria are satisfied, that the test approach is consistentwith the MTP, and that all test design elements (e.g., data collectiontools, evaluation criteria, interview guides, test cases, etc.) aresufficiently developed for testing to proceed. Peer reviews arepreferably conducted according to predetermined peer review guidelinesconcerning the selection of appropriate peers, scheduling andcommunications protocols, topics of discussion, escalation protocols,and the like. Although peer review are desirable and should serve toenhance the reliability of the test, and may be required in certainembodiment, peer reviews may be omitted in other embodiments.

Entrance criteria are those requirements that must be met beforeindividual tests can begin. Global entrance criteria, which may apply toeach individual test, may include but are not limited to: (1) a detailedtest plan has been approved by the regulatory entity; (2) any pendinglegal or regulatory proceedings that might impact the ability to performthe test have been concluded in a manner that allows testing to proceed;(3) the regulatory entity has verified measurements to be used in thetest, which sufficiently support collection of test results; (4) allpertinent ILEC interfaces have been tested and operationally ready; (5)all the pertinent pseudo-CLEC and/or CLEC interfaces have been testedand operationally ready; and (6) CLEC facilities and personnel areavailable to support elements of the test plan requiring CLECinvolvement. In addition to these or any other global entrance criteria,one or more test-specific entrance criteria may be defined for each testas appropriate.

Test activities 28 b may include initiating and satisfying formal datarequests, conducting required formal interviews and verifying interviewreports, conducting analyses, verifying analysis results, submittingexceptions, compiling a draft report, and conducting an exit reviewprocess.

An example data request process through which the testing entity maysolicit information from the ILEC 14 and/or CLECs 16 (referred tocollectively as “LEC”) depending on the particular test, is illustratedin FIG. 4. In one embodiment, all materials that are not publiclyavailable should be sought using a formal, written data request. Awritten data request should be used when the information requested mustbe provided within a specified timeframe or when traceability isessential (i.e. the working papers need to show that the appropriateILEC source provided a complete and current version of the informationrequested). As just example, one should not assume a file copy of aninternal procedures document is the most current version without theconfirmation provided by a written data request. A standard data requestform is preferably made available to all testing entity personnel tohelp streamline and standardize information requests across all tests.One or more test-specific or other more particular data request formsmay also be provided.

An example interview process, by which the testing entity interviewsILEC and/or CLEC personnel depending on the test, is illustrated in FIG.5. In one embodiment, there are two categories of interviews—formal andinformal. Informal interviews take place outside active testing; forexample, background conversations with ILEC and CLEC representatives.Formal interviews take place during active testing; participants informal interviews are considered “on the record” for testing purposes.Interviewing guidelines developed by the testing entity may provide theinterview parameters and instructions for testers conducting formalinterviews, and should preferably not be distributed to ILEC 14, CLECs16, or any other external party. Certain interview guidelines regardinginterview protocol and documentation may apply to informal interviews aswell as formal interviews. Each interview team (e.g., for each test oreach domain) may develop a more specific interview guide, including aset of test-specific or domain-specific questions, based upon thegeneric interview guidelines.

Notes should be taken at each interview and, following the interview,all test team notes may be compiled into a detailed internal interviewreport which further includes any handouts or written material providedduring the interview. Interview reports are preferably not distributedto the interviewees. However, a brief summary of each interview may becreated to record key facts provided during the interview and thenforwarded to the interview participants. This provides interviewees withan opportunity to review and confirm their statements in writing. Thesummary should preferably not include any test conclusions or analysis.Once comments from the interview summary are received in writing, or thetime to respond has elapsed, the interview summary may be finalized.Testers are not obliged to provide an amended version of the interviewsummary based on written or verbal comments. However, original writtencomments may be included in the working papers for the test. Anyfollow-up conversations directly relating to a formal interview may berecorded as an addendum to the interview report or as a note to thefile.

Situations may arise in which the scope of a test as defined in the MTPwill need to change. For example, additional tests or modified tests maybe required in order to meet the overall objectives of the testingprocess. The testing entity may be responsible for instituting andenforcing change control procedures to accommodate these circumstances.If a change to the test appears necessary, the responsible partiesshould prepare a change proposal containing a description of the changed(or new) test case; a justification for the proposed change;identification of one or more test domains, scenarios, test processes,and test cases impacted; revised text for pertinent test plan sectionsand test reports; identification of resource and schedule impacts; orany other suitable information. A change control number may be assignedto each change proposal. All changes to the MTP should preferably beapproved by testing entity management, the ILEC 14, and the regulatoryentity before being incorporated into active testing, for example, usinga standard “sign-off” approval form.

In process peer reviews are conducted on an elective basis during theactive phase of a test. These are most appropriate when the scope of atest has changed materially. In process peer reviews may be conductedaccording to the same peer review guidelines as the peer reviewsassociated with entrance and exit reviews. In contrast to entrance andexit reviews, which in one embodiment may require formal “sign-off”approval, since in process peer reviews are elective they do not requiresuch approval.

The exit review process may be analogous to the entrance review processillustrated in FIG. 3, and preferably includes a peer review component,which as discussed above may be a required aspect of an exit review. Inone embodiment, an exit review is required to complete a test. Theprimary purpose of this review is to ensure the test has been conductedconsistent with the test plan, that test results are appropriatelyreported and supported, and that exit criteria are satisfied.

Evaluation measures and corresponding evaluation criteria provide thebasis for conducting tests. In general, evaluation criteria include thenorms, benchmarks, standards, and guidelines used to evaluate themeasures identified for testing. The evaluation criteria provide aframework for identifying the scope of testing activities, the types ofmeasures to be made during testing, and the approach used to analyzeresults. Test results are compared against evaluation criteria to assessthe ILEC's performance. Evaluation measures and associated criteria maybe identified by the testing entity using its professional judgment, theregulatory entity, or the testing and regulatory entities in concert. Anevaluation checklist may be created for each test based on theevaluation criteria for the test, for use by testing entity personnel inconducting testing activities and evaluation ILEC performance withrespect to the evaluation criteria. After an evaluation checklist isdeveloped for a specific test, it should be reviewed during thecorresponding entrance review. Once reviewed, the checklist ispreferably subject to formal change control procedures, at least as toany material changes. For example, changes made in order to clarify themeaning or to facilitate results reporting, without changing the scopeof the test, may not be subject to formal change control procedures.

In a particular embodiment, types of evaluation criteria may include,without limitation: (1) quantitative, which set a threshold forperformance where a numerical range is possible (e.g., response time isfour seconds or less); (2) qualitative, which set a threshold forperformance where a range of qualitative values is possible (e.g., thedocumentation defining daily usage feeds is adequate); (3) parity, whichrequire two measurements to be made and compared (e.g., CLEC transactiontime is not greater than the ILEC retail transaction time); and (4)existence, where only two possible test results (e.g., true/false,presence/absence, etc.) can exist (e.g., documentation defining dailyusage feeds exists). In cases in which a metric or an associatedstandard does not exist or the testing entity determines that thestandard provides a competitive advantage either to ILEC 14 or the CLECs16, the testing entity may recommend a new standard to the regulatoryentity. In general, all evaluation criteria are not of equal importance.Some may be less important as standalone measures, but may besignificant when viewed with other evaluation criteria. Others may besignificant in their own right. Thus, simple numerical counting oraveraging of test results for one or more domains or tests may bemisleading and should be avoided.

For certain tests, testing entity may rely on statistical methods toconduct its analyses and render conclusions about ILEC performance. Thetest plan for each test for which a statistical analysis is used shouldpreferably define the data population to be observed, the measurementsto be taken, and the statistical techniques to be used. Data should betabulated and archived in a way that allows verification of test resultsand re-analysis of data using the same or alternate statistical methods,if appropriate. In instances in which sampling is used, sampling shouldbe designed so that samples are sufficiently representative of datapopulations with respect to the measures being studied to ensure thatthe resulting statistical inferences made about the populations arevalid and reliable.

In one embodiment, testing employs a hypothesis testing approach toframe the analysis of test results. In this approach, the “null”hypothesis is that ILEC 14 is meeting the relevant performance standard(i.e. it is assumed that parity exists). The null hypothesis will berejected if the differences in the ILEC and CLEC statistics arestatistically significant at a suitable significance level (e.g., at the5% significance level). For metrics that require a particularperformance standard, a one-sample t-test will typically be used forcontinuous variables (e.g., response time) and a binomial test willtypically be used for discrete variables (e.g., whether an appointmentwas missed). For metrics requiring parity, a two-sample t-test willtypically be used for continuous variables and a hyper-geometric testwill typically be used for discrete variables. For samples of small ormoderate size, where the variable is continuous, a permutation test maybe used. There may be instances where tests described above are notappropriate, due to assumption violations or other anomalies in thedata. In these situations, other statistical methods and tests should beused as appropriate. Test results for a test will preferably include asummary of any statistics calculated, the hypotheses postulated for thetest, the conclusion drawn based on the statistical results, and thesignificance level or p-value for the test.

In one embodiment, as opposed to a one-time “pass/fail” evaluation ofthe ILEC's OSSs 12, the testing entity implements a “military-style”test approach that incorporates a “test until you pass” mindset. Thisphilosophy may help ensure that a baseline set of working componentswill be available to CLECs 16 at the end of the testing period. Thiswill often be in the best interest of all parties seeking an opencompetitive market for local telecommunications services. However, thisphilosophy will generally lengthen the testing period due to the need toiterate through the test, fix, and retest cycle, sometimes more thanonce per component tested.

In one embodiment, for each component tested, the test process proceedsas follows: (1) the testing entity tests the component; (2) the testingentity informs ILEC 14 of any problems encountered by generating awritten “exception” describing the failed component and the potentialimpact on CLECs 16; (3) ILEC 14 prepares a written response to theexception describing any intended fixes; (4) after the ILEC fixes arecompleted, the testing entity retests the component as required; (5) ifthe exception is cleared, the test process is considered complete as tothe component and the testing entity prepares a written closurestatement; and (6) if the exception is not cleared, the testing entitycontinues to iterate through the test, fix, re-test cycle until closureis reached. While a military-style testing philosophy is primarilydescribed, the present invention contemplates relaxing theserestrictions if appropriate, whether on a global,component-by-component, or other basis. For example, the testing entitymay determine that a component will not be subject to any furtherre-testing, despite lack of closure, in which case the test results forthe component will remain in a less than fully satisfied state.

Exceptions are results that do not meet the evaluation criteria orperformance standards established for a test. Exceptions may beprocessed in a formal manner as described below. An exception should bedocumented in detail, including all details necessary to substantiatethe exception, and reported as soon as it can be adequatelysubstantiated. In one embodiment, once initially documented, theexception may be considered a draft exception until it is approved andreleased, for example, by a test domain lead or other suitableindividual. All draft exceptions are submitted to the ILEC 14 to provideILEC 14 with an opportunity to verify the facts supporting theexception. All draft exceptions may be assigned an exception ID andplaced on a master list of exceptions. ILEC 14 is provided a time periodto refute any factual inaccuracies in the draft exception. A draftexception may be withdrawn based on ILEC feedback. If an exception isnot withdrawn at this stage, it becomes a pending exception.

The ILEC 14 may be required to respond in writing to all pendingexceptions. The pending exception and the ILEC's initial writtenresponse may be reviewed, for example, in a formal meeting or conferencecall in which the regulatory entity is a required participant. CLECs 16or other interested parties may also be participants. Subsequent to thisformal review, the pending exception may be withdrawn. If the pendingexception is not withdrawn at this stage, it becomes an open exception.The ILEC 14 may elect to amend its initial response and provideadditional data and documentation subsequent to the pending exceptionreview. All ILEC 14 responses to exceptions should be made part of theworking paper record for the test.

In one embodiment, one or more members of the applicable test team mustreview and assess the ILEC's initial and subsequent written responses toexception. This review may include verifying that all aspects of theexception are addressed in the responses and ensuring that all proposedresolutions to responses are supported through data and documentationprovided or are verifiable through retest activities. If the response isincomplete or does not provide a basis for retesting, the ILEC 14 isnotified that the exception resolution process cannot proceed. If abasis for retesting is established, retesting activities are performed.

There may be two possible avenues for active exceptions to be processed:(1) an open exception is closed out when retesting is completed withsatisfactory results; or (2) an open exception may be deferred to endtest activities in the absence of a satisfactory test result where thereis no reasonable expectation that a resolution can be reached. Forexample, if the ILEC 14 commits to resolve the negative test resultscited in an exception, but does not or cannot demonstrate correctiveaction during the test period, a deferral is in order. An exceptionshould not be deferred without the prior approval of an appropriateindividual. ILEC 14 may be required to propose a new resolution if apreviously proposed resolution is not achieved or not achievable. Testreports should include all exceptions noted, retesting results, andwritten ILEC 14 responses.

Example exceptions processes, providing further detail, are illustratedin FIGS. 6A and 6B. The processes of FIGS. 6A and 6B may be separatealternatives to one another or may be combined in whole or in part inany appropriate manner according to particular needs. Although an SPSCis shown, as discussed above, the present invention contemplates anysuitable regulatory entity, depending on the jurisdiction in whichtesting is conducted.

The exceptions process being used may be supplemented where appropriatewith an observations process, which may supply a key component formeeting two criteria for independent third-party testing of the ILEC'sOSSs 12. First, the process establishes a structure and mechanisms bywhich the “test until you pass” philosophy described above can function.Testers can generate preliminary observations and, according to asystematic process, these observations are communicated to ILEC 14,responses are solicited, ILEC 14 takes appropriate actions, andre-testing can occur. Second, the process creates a forum by which CLECs16 and other interested parties can monitor the test and comment onspecific findings. The observations process is therefore advantageous asan extension of the exceptions process.

Observations are created where the testing entity determines that asystem, process, policy, or practice characteristic of ILEC 14, asrevealed by a test, might result in a negative finding in the final testreport. In one embodiment, there are two types of observations,differentiated by the certainty of the existence of a problem. The firsttype of observation is a question regarding an area of an ILEC componentbeing tested that cannot be answered without additional guidance fromthe ILEC 14. The source of the confusion is described in an observationdocument. This type of observation is meant to clarify issues, and willeither be satisfactorily answered by the ILEC 14 and closed by thetesting entity, or upgraded to a traditional observation or exception bythe testing entity in view of the ILEC's response. The second type ofobservation is a means of identifying what may be a potential deficiencyin an ILEC component that could contribute to a negative finding in thefinal report if validated and left unresolved. Observations are meant toalert the ILEC 14, and all concerned parties, to the existence ofpotential deficiencies so that they can be addressed in a timely andsatisfactory manner. ILEC 14 may be permitted to resolve observationswith workarounds until permanent fixes can be implemented. In contrast,exceptions identify deficiencies in ILEC components that will result ina negative comment for one or more evaluation criteria in the finalreport if left unresolved. Observations may not become exceptions, andcertain exceptions may not have been identified previously asobservations.

For example, an observation report may have a unique identifier and mayspecify the date it was issued, the particular jurisdiction to which itis applicable, its owner (e.g., the specific testing entity), the roleof the owner (e.g., “Test Manager” where the owner is the testingentity), and the particular test to which it pertains if appropriate.The observation report describes the general nature of the observation,the specific issue and how it arose, and a brief assessment of theimpact of the issue on the ability of CLECs 16 to compete in the marketfor local telecommunications services. Other suitable information may beincluded if appropriate.

Observations may be handled similar to exceptions in terms ofsubmission, review, resolution, etc. if desired. However, certaindifferences in treatment may be present in a particular embodiment. Inone embodiment, once initially documented, the observation may beconsidered a draft observation until it is released. Once the draftobservation is posted, it becomes an open observation and may bereported to ILEC 14, posted on a website accessible to CLECs 16 or otherinterested parties, or otherwise distributed. Each observation may beassigned an observation ID and be placed on a master list ofobservations.

A weekly or other conference call will be held to enable the testingentity, the ILEC 14, CLECs 16, the regulatory entity, and otherinterested parties to discuss open observations. These parties willpreferably be able to ask clarifying questions during the calls. Thetesting entity may record minutes of conference calls held for eachobservation. These minutes may include the status of each observation aswell as action items that arise during the conference call. The officialminutes from each conference call may be posted on a website orotherwise distributed. The ILEC 14 may be invited to respond in writingto an observation, although a verbal responses may be sufficientdepending on the circumstances. This request may be made when theobservation is first released to ILEC 14 or after discussion of theobservation on the conference call. In either case, ILEC 14 will have aspecified number of business days, after being notified that a writtenresponse is requested, in which to provide a written response. ILEC 14may also have the option to initiate a written response to anobservation. These responses should describe either a clarification ofthe issues identified in the observation or the ILEC's intended fixes tothe problem. Written responses from ILEC 14 may be posted on a websiteor otherwise distributed.

An observation can progress from open to closed status if the testingentity determines that the investigation of the observation iscompleted. Such investigation may include any retest activities thatresult from the ILEC's response. Additionally, an observation may beescalated to an exception if the testing entity determines that theissue would result in a “Not Satisfied” evaluation of one or moreevaluation criteria defined for a particular test.

A central library for exceptions and/or observations may be establishedfor comprehensive cataloging, tracking, and reporting of exceptionsand/or observations across multiple tests, test domains, andjurisdictions. This exceptions/observations library may be supportedusing any suitable database(s) at one or more locations. As an example,the library may be contained in a database associated with a web serverthat communicates Hypertext Markup Language (HTML) pages to interestedparties over the Internet. The actual exceptions and/or observationreports may be made available where appropriate. In addition, trackinginformation may be available for each exception and/or observation,including a brief description, classification (e.g., (e.g.,active/inactive), status (e.g., deferred), status reason (e.g., “Resumediscussion Jun. 26, 2001”), historical notes compiled since its initialissuance, any related exceptions and/or observations, and any othersuitable information. This library may also be used advantageously as aflexible change or program management tool with respect to ILEC OSStesting.

In one embodiment, each evaluation criterion is analyzed separately andhas its own associated test result and comment (where appropriate). Testresults may fall into the following categories, without limitation: (1)“satisfied”—meaning that the evaluation criterion was satisfied; (2)“satisfied, with qualifications”—meaning the evaluation criterion wassatisfied but one or more specific areas need improvement; (3) “notsatisfied”—meaning the evaluation criterion was not satisfied in thatone or more issues were identified that would have some business impacton CLECs 16, whether or not an exception is also generated; (4)“satisfied, exception resolved”—meaning that the evaluation criterionwas not initially satisfied, an exception was generated, ILEC 14 madeone or more fixes, and the evaluation criterion was then satisfied; and(5) “satisfied, with qualifications, exception addressed”—the evaluationcriterion was not initially satisfied, an exception was generated, theILEC 14 made one or more fixes, and the criterion was then satisfiedwith qualifications. These categories are merely examples; test resultsmay be classified in any suitable manner according to particular needs.

In contrast to entrance criteria, exit criteria are the requirementsthat must be met before the individual tests can be concluded. Globalexit criteria, which in one embodiment may apply to each individual testunless otherwise noted, may include but are not limited to: (1) allrequired fact-finding, analyses, and other test activities arecompleted; and (2) all appropriate change control, verification, andconfirmation steps are completed, including documentation and review oftest results for accuracy and confirmation of any test results thatrequire clarification. In addition to global exit criteria, one or moretest-specific exit criteria may be defined for each test as appropriate.

Post-test (“close-out”) activities 28 c may include satisfying remainingexit criteria, closing out resolved exceptions, completing workingpapers, completing a final report, and conducting one or more finalreviews. An example final report preparation process is illustrated inFIGS. 7A and 7B. This process preferably includes a substantial peerreview component, since the final report will become the basis for theregulatory entity to determine the compliance of ILEC 14 with the 1996Act of other applicable regulatory framework as to the particular testfor which the final report is prepared.

Pop Domain

In general, pre-order processing involves CLEC submission of requests toILEC 14 for information that CLEC 16 needs to complete orders, orderprocessing involves CLEC submission of orders to ILEC 14 to initiate ormodify one or more aspects of a CLEC customer's service, andprovisioning involves the work ILEC 14 must perform to implement thesubmitted orders. The POP Domain encompasses a variety of tests designedto provide a comprehensive review of systems, processes, and otheroperational elements associated with the ILEC's support of POPactivities for its wholesale operations. The purpose of these tests isto evaluate functionality, evaluate compliance with measurementagreements, and provide a basis to compare the ILEC's support in thisarea to parallel systems, processes, and other operational elementssupporting the ILEC's retail operations. In short, the tests aredesigned to evaluate whether the CLECs 16 receive a level of servicecomparable to the ILEC's retail service with respect to POP Domainactivities. The report generated by the testing entity should allow theregulatory entity to assess the net impact of any POP-related problemsthat it identifies on the ability of CLECs 16 to function in an opencompetitive environment in the state or other jurisdiction of interest.

In one embodiment, the POP Domain may be broken down into a number oftest target areas that collectively encompass, without limitation,pre-order processing, order processing, order flow through,provisioning, metrics, documentation, help desk support, andscalability. Each of these test target areas may be further broken downinto increasingly discrete process and sub-process areas that identifyparticular areas to be tested and types of measures that apply to eacharea. According to the present invention, one or more tests aredeveloped to evaluate each test target area based on the scope oftesting to be performed in each area. There may not be a one-to-onecorrespondence between test target areas and specific tests designed toevaluate test target areas. In a particular embodiment, the POP Domaintests may include, without limitation: (1) an EDI InterfaceCertification Test, (2) an EDI Interface Functional Test, (3) a GUIInterface Functional Test, (4) an Order Flow Through Test, (5) a LiveCLEC Functional Test, (6) a Manual Order Process Test, (7) a MetricsTest, (8) a Documentation Test, (9) a Help Desk Test, (10) aProvisioning Parity Test, (11) a Provisioning Coordination Test, and(12) a Scalability Test. Embodiments of these tests are described below.

A. POP EDI Interface Certification Test

As described above, all CLECs 16 entering the local market mustestablish some form of connectivity with ILEC 14 to submit pre-order andorder transactions. This connectivity can be automated (e.g., an EDIinterface or GUI) or manual (e.g., telephone calls and faxes). This testis designed to certify that CLECs 16 are able to submit valid pre-ordersand orders and receive suitable responses using the ILEC's EDItransaction interface. Accordingly, the testing entity must provide thepseudo-CLEC 18 with systems and processes suitable to model theoperating environment of a new CLEC 16 and its interfaces to ILEC 14.The testing may require extensive coordination between ILEC 14 and oneor more CLECs 16. In a live production environment, the ILEC's processesand procedures for supporting CLEC interface development efforts, whichincludes support related to certification testing, may be assessed aspart of RMI Interface Development Verification and Validation Testdescribed below. This test preferably complements that RMI test byverifying and validating the ILEC's procedures through actualcertification testing. In general, this test uses a non-exhaustive setof pre-order and order test transactions, representative of transactionsexpected to be submitted in the ILEC's live production environment.Although described primarily in the context of EDI formattedcommunications, the present invention contemplates the transactions andresponses being in Extensible Markup Language (XML) or any other formatappropriate for computer-to-computer communications.

Referring to FIG. 8, CLECs 16 may access pre-order information from andsubmit order requests to ILEC 14 electronically using one or more ILECEDI interfaces 30, GUI interfaces 32, or manual interfaces 34, asappropriate, all of which may be encompasses within ILEC OSS accesssystems 20. For testing purposes, the pseudo-CLEC 18 may interact withthese interfaces using one or more transaction engines 36, GUIs 38, ormanual entry positions 40, respectively. Orders that “flow through”(indicated by arrows 42) are passed to one or more order processors 44and on to provisioning systems 46, one or both of which may beencompassed within the ILEC's OSSs 12. Orders that do not flow through(indicated by arrows 48) are instead diverted to manual interface 34,which may be associated with an operations center of ILEC 14, forhandling. Manual interface 34 may also orders submitted by telephone,fax, or other “manual” methods. One or more help desks 50 may handlequestions, requests, and other communications from CLECs 16 (in thiscase from pseudo-CLEC 18) associated with pre-order and orderprocessing. One or more suitable changes may be made to the illustratedembodiment without departing from the scope of the present invention.

CLECs 16 submitting pre-orders and orders to EDI interface 30 are likelyto build front-end applications that make the system more efficient anduser-friendly. These applications may be designed to provide a more“readable” format than EDI affords so as to reduce the time required forCLEC 16 personnel to process the order information and reduce thepotential for such personnel to introduce errors into the orders. Forany CLECs 16 that are attempting to integrate EDI pre-order and orderprocesses, efficiencies can be achieved by automating the population oforder input fields with the information returned in a correspondingpre-order response.

ILEC 14 provides test bed accounts against which pre-order and ordertest transactions may be placed. Preferably, ILEC 14 will publish aguide describing the transport format for EDI transactions and providingbusiness rules specifying how pre-orders and orders should bestructured. In one embodiment, using this or other suitable information,transaction engine 36 is established within pseudo-CLEC 18 to build theindividual test transactions, based at least in part on the availabletest bed accounts, and submit the transactions to ILEC 14 forprocessing. Transaction engine 36 may populate pre-order and order datafields in a text or other suitable file. Prior to submission to ILEC 14,the pre-orders and orders may be translated from text to EDI format.Responses from ILEC 14 may be similarly translated from EDI format backinto text for processing at pseudo-CLEC 18.

FIG. 9 illustrates an example EDI interface certification test process.The process begins at step 60, where ILEC 14 provides access to itssubject matter experts (SMEs) and other personnel using an openconference bridge or any other mechanism to enable the testing entity touncover errors and make appropriate modifications in connection withcertification testing. At step 62, the testing entity designs pre-orderand order transactions based on test cases derived from test scenarios;knowledge it acquires during ILEC-provided training, ILEC businessrules, or EDI documentation; and any other appropriate information. Inone embodiment, orders are in the form of Local Service Requests (LSRs),although any suitable order format may be used. At step 64, pseudo-CLEC18 generates and submits an appropriate pre-order or order transactionto ILEC 14 in EDI or another suitable format. In one embodiment, thetransaction is generated and submitted automatically using thetransaction engine 36, and transaction engine 36 logs the submittaldate, time, and appropriate transaction information. Transactions may begenerated in a proprietary format for conversion into EDI or anotherformat for submission to the ILEC 14. Testing involving certaintransactions may be conducted separately if they cannot be automaticallygenerated using transaction engine 36.

Test case writers of the testing entity may construct test cases, whichare the templates used to develop the actual test instances (pre-orderand order transactions), according to specified requirements. Forexample, the testing entity may require the test case writer to haveavailable all forms and fields in current pertinent industrydocumentation, such as Local Service Ordering Guide (LSOG) documentationin the United States defining pre-orders and orders. Test case writersmay determine the forms as needed by selecting a type of order,selecting the individual forms, or both, and may modify existing formsas appropriate. Requirements for field population may include, withoutlimitation: (1) that every field on a form must have an action assignedto it—“Static” where the value is the same for each test instancegenerated, “Dynamic” where the value is populated at instance generationusing the test bed, “Run-Time” where the value is populated by a testerbefore instance submission, and “Blank” where no value will be assignedto the field; (2) that “Blank” is the default value for all fields; (3)that fields designated as “Dynamic” will be shaded a suitable color forthe life of the test case and all of its instances to allow for easierchecking of auto-population; and (4) that fields designated as“Run-Time” will be shaded another color for the life of the test caseand all of its instances, with each such field needing to be filled inbefore submission of the instance. In one embodiment, before ordersubmission, one or more run-time check requirements may need to besatisfied. For example, before an order is submitted, a checks may beperformed to verify that all “Run-Time” designated fields are populated.If such a field is empty, the order may be allowed to be submitted onlyif the missing field is for a planned error (checked according to apurchase order number (PON) or otherwise). Alternatively, a warning maybe generated while still allowing the order to be submitted. Suitabletest bed information (e.g., new telephone number) may be automaticallyentered into a pre-order or order using a suitable tool. In oneembodiment, test cases may be generated using one or more templatesaccording to the example process illustrated in FIG. 10. While an ordertemplates review process is shown, the process may apply to any suitablepre-order, order, or other test cases.

At step 66, the ILEC 14 receives and processes the transaction using oneor more ILEC OSSs 12 and, at step 68, returns an EDI or other suitableresponse. Some or all of the transactions may be processed by an ILEC 14quality assurance or other test system that is separate from the ILEC'sproduction system. Instead, some or all transactions may be sent to theILEC's production system in a “training mode.” Use of the training modemay allow pseudo-CLEC 18 to more easily submit numerous transactionsagainst a single test bed account. Orders submitted in training mode donot typically flow through and thus do not typically proceed beyondorder processor 44 to provisioning systems 46. Transactions may begenerated at pseudo-CLEC 14, submitted to ILEC 14, and processed at theILEC 14 serially, concurrently, or in any other suitable manner.

At step 70, pseudo-CLEC 18 receives the response using transactionengine 36, perhaps after conversion from EDI or another format in whichit was generated into a proprietary format, and records the date, time,transaction type, and condition (e.g., valid vs. reject) for theresponse. Transaction engine 36 may attempt to match the response to theoriginal transaction (recording any mismatches) and may verify that theresponse contains expected data (flagging non-expected errors). Thesource of any errors may be determined manually and recorded. Help desk50 may be used for unexpected errors, as indicated in test casesassociated with the POP Help Desk Test described below, following theappropriate resolution procedures.

The response may be a confirmation or an error message. A confirmationis generated in response to ILEC 14 successfully processing an order oran associated pre-order and assigning a corresponding order number. Anerror message is instead generated in response to the ILEC 14encountering an error in the order or pre-order. As just an example, anorder confirmation may be in the form of a Local Service Confirmation(LSC) and an error message associated with an order may be in the formof a Standard Error Message (SEM), although any suitable format may beused according to particular needs. At step 72, if the response is aconfirmation indicating successful processing of the transaction, theprocess is typically completed as to that transaction and the processproceeds to step 78.

If the response is instead an error message at step 72, then thepseudo-CLEC 18, the ILEC 14, or both may research the error at step 74in the manner described above for mismatches. At step 76, correctionsmay be made and the process returns to step 64 where the transaction maybe re-submitted if appropriate. The process iterates in this manneruntil a confirmation is received from the ILEC 14. At least some, andperhaps most, errors will need to be corrected through trial and error,with corrections being attempted multiple times prior to successfulprocessing. Example processes to be performed (1) before an order issubmitted and (2) in submitting an order are illustrated in FIGS. 11Aand 11B, respectively. The processes may be combined with, maysupplement, or may replace the process of FIG. 9 in whole or in partaccording to particular needs.

Testers associated with the testing entity may be required to assign areason code to each transaction for which an error message is received.It may be desirable to provide an error log tool that is automaticallypresented when a tester selects an order (such as by clicking on afolder corresponding to the order through a GUI) or attempts to createan error-correction document. For example, the tester might be forced toprovide an error message reason code in the error log before beingallowed to create the error-correction document. The error log may bemade electronically available to a help desk tracking system, a metricsdata collection system, or one or more other suitable systems. Moreover,since much of the intelligence about a test instance may eventually beincluded in a “Comments” field, it may be desirable to providestandardized comments that testers can input into “Comments” fields(e.g., “Cancel via LSC”). If network problems occur or responses arelost in the “Status” field, the “Comments” field may still besearchable. Such standardized comments may also streamline statuscompilation and increase accuracy of reporting.

Since testers should track all order errors received and assigncorresponding reason codes, and since help desk 50 is used when a testercannot resolve an error, linking the tester error log with help desk 50may be desirable. Automating both processes and making them available totesters through an associated GUI may also be desirable. For example,one or both processes may be implemented as a desktop applicationthrough which a tester may receive an error message for an order, select“Enter Error Info” or the like, provide appropriate information, andselect “Send to Help Desk” or the like if needed, in which caseinformation may be automatically routed to a database associated withhelp desk 50.

A problem may occur if a planned error-correction document is never sentbecause a tester forgets that there is such a planned error-correctiondocument in the test instance folder. As an example, the ILEC 14 mightreturn a confirmation and eventually generate a notification ofcompleted provisioning, but with one or more versions of theerror-correction document never having been sent. Therefore, it may bedesirable to provide an automatic reminder that may be generatedperiodically to remind testers to submit planned error-correctiondocuments. As a further safety measures, it may be desirable to providea mechanism to automate the tracking of what is actually provisioned toensure that it matches was what ordered. Absent an automated mechanism,verification may be performed manually. Another desirable feature mayinclude alerting the testers when confirmations and/or notifications ofcompleted provisioning are past due.

At step 78, the testing entity records any suitable test events and datanot already recorded, such that substantially complete transactionhistories are preferably maintained. If a response is not received for atransaction, this should be identified and recorded. If multipleresponses are expected for the same transaction (e.g., a pre-orderrequest), then each response may be monitored separately. Jeopardy anddelay notifications may be received and recorded using transactionengine 36 or otherwise. Orders may be provisioned as part of this testif appropriate, these activities being addressed as described below inconnection with other POP Domain tests. The testing entity uses therecorded information at step 80 to assess the ILEC's performance withrespect to the test target areas described below, generating one or moreappropriate reports, and the process ends.

Reports may include a carrier-to-carrier report to ILEC 14. Reports mayalso include, without limitation: (1) metrics supporting standards ofperformance defined in applicable agreements; (2) variance betweenactual performance and standards of performance defined in applicableagreements; (3) expected results vs. actual results; (4) unexpectederror count by type and percentage of total; (5) rejects received afterconfirmation notification and percentage of total; (6) unexpected errorsas a result of documentation problems; (7) transaction counts, errorratio, response time, and other metrics by transaction type, productfamily, delivery method, or another appropriate category; (8) minimum,maximum, mean, average, and aggregate response interval per transactionset; (9) transaction counts per response interval range per transactionset; (10) orders erred after initial confirmation; (11) flow-throughorders by order type, product family, delivery method, or otherappropriate category; (12) completed help desk logs and checklists; (13)completed provisioning logs and checklists; (14) completedjeopardy/delay notification logs; (15) help desk accuracy andtimeliness; (16) provisioning accuracy and timeliness; (17) comparisonof pseudo-CLEC 18 to one or more CLECs 16; (18) measurements pertainingto transaction engine 36; (19) measure of parity performance betweenretail and wholesale; and (20) a summary of appropriate test activities,results, and conclusions.

Any suitable test scenarios may be used for certification testing,according to particular needs. In one embodiment, these may include,without limitation, scenarios 1-38, 41-46, 54, 56-58, 60-61, 64-66, 70,74, 76-82, 84-85, 92-94, 96-97, 102-105 107, 116-122, and 125-130 listedin Appendix A. Specific scenarios may be used to validate certain flowthrough capabilities. Details of the specific test case for a givenscenario, such as the specific service delivery method and the type oflisting, impact whether a test case is flow-through. Example flowthrough test cases are listed in Appendix B. Flow-through testing isdescribed below in connection with the POP Order Flow Through Test.

Test target areas and associated evaluation measures are summarized inthe table below. Evaluation criteria for these measures may include, inany appropriate combination and without limitation: (1) the ILEC 14provides an effective and well-defined process for planning andcoordinating certification testing activities; (2) ILEC 14 provides astable test environment segregated from production and developmentenvironments; (3) the ILEC 14 provides suitably responsive and effectivetechnical assistance to CLECs 16 during the certification process; and(4) the ILEC-provided interface specifications are sufficiently completeand accurate to allow CLECs 16 to carry out certification testing. Thelast column of the table indicates how particular evaluation criteriamay, in one embodiment, correspond to the particular evaluationmeasures.

Test Target Areas and Measures

Process Area Sub-Process Area Measures Criteria CLEC Support for ILECAdequacy and completeness 1, 3 interface interface develop- ofcertification testing certification ment and testing process testingefforts Adequacy of documentation 4 Adequacy and capability of 2interface test environments

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

B. POP EDI Interface Functional Test

This test evaluates ILEC systems, processes, and other operationalelements associated with the ability of ILEC 14 to provide CLECs 16 withnon-discriminatory access to the ILEC's OSSs 12 with respect topre-order and order transactions. The evaluation is designed to assessthe ability of the ILEC 14 to accurately process such transactions andsmoothly support normal and peak transaction volumes for CLECs 16entering the market for local telecommunications services. This testinvolves end-to-end processing of pre-order and order requests thatCLECs 16 submit using the ILEC's EDI or other automatedcomputer-to-computer transaction interface. In order to measure theability of ILEC 14 to provide CLECs 16 with suitable functionality andservices, the test models the interaction between CLECs 16 and ILEC 14using pseudo-CLEC 18.

As described above, ILEC 14 provides test bed accounts against whichpre-order and order transactions may be placed. In one embodiment,transaction engine 36 is used to generate and submit individual testtransactions. Prior to live testing, various aspects of the CLEC-ILECinterface will preferably be certified as described above in connectionwith the POP EDI Interface Certification Test. The test cases and actualtest transactions may be developed based on test scenarios as describedabove. Some or all of the test scenarios described in connection withthe POP EDI Interface Certification Test may be used. The test cases andtest transactions will preferably span a variety of business andresidential customer needs, a variety of service families (e.g., POTS,ISDN, Centrex), a variety of service delivery methods (e.g., resale,UNE-P, UNE-L), and any other variables to provide suitable coverage. Thesame test cases and test transactions may be used for normal, peak, andstress volume testing.

In addition to simulating CLEC systems and requirements, the testingentity should preferably attempt to replicate the operational and volumepatterns of a real CLEC 16. Exemplary techniques might include, withoutlimitation: (1) submitting transactions primarily during documented CLECoperational hours; (2) submitting some transactions outside ofdocumented CLEC operational hours to further test the ILEC 14; (3)intentionally submitting some transactions with errors; (4) submittingtransactions requiring ILEC 14 to respond from multiple COs, multiplecities, and locations supported by different work groups; and (5)submitting transactions at both normal, peak, and stress volumes to testILEC 14 under various conditions.

Because the test is conducted with the testing entity acting as apseudo-CLEC 18, it is important that the test processes be mapped,without interference, to the transactional processes that CLECs 16normally encounter in doing business with ILEC 14. The two transactionalprocesses central to this test are (1) the pre-order process, and (2)the order and provisioning process. These processes interrelate in thatdata from transactions conducted pursuant to the pre-order process maybe used to initiate some transactions in the order and provisioningprocess. However, not every transaction in the order and provisioningprocess relies upon a preceding pre-order transaction. Additionally, atleast some integrated pre-order/order transactions may be conducted inwhich information returned in a pre-order response is copied, withoutmodification, into a corresponding order request. This may highlight anyinconsistencies in field names, formats, and other information betweenthe pre-order responses and order requests.

FIG. 12 provides an overview of these transactional processes, involvingthe sharing of information between pseudo-CLEC 18 and ILEC 14. In anactual CLEC 16 environment, CLEC 16 populates a pre-order request orother form with information collected from the CLEC customer. Thepre-order process allows the CLEC 16 to verify the availability ofparticular services and delivery dates, validate some or all of thecustomer information, and reserve any telephone numbers before actuallyplacing an order. In one embodiment, pre-order and order testtransactions are created and loaded into transaction engine 36 to befinalized and automatically submitted on one or more scheduled datesdetermined prior to the start of the test. The loading, formatting, andtime-stamping of transactions, as described more fully below, preferablyoccurs in batch mode, although these activities may occur in anysuitable manner according to particular needs. One or more changes maybe made to the embodiment illustrated in FIG. 12 without departing fromthe intended scope of the present invention. As an example, a formatother than EDI may be used for automated communications betweenpseudo-CLEC 18 and ILEC 14.

A pre-order transaction is prepared (100) and submitted (102) to ILEC 14using transaction engine 36. Transactions may be generated attransaction engine 36 in test file format, converted from text fileformat to EDI format within transaction engine 36 or a different system,time-stamped, and then forwarded to ILEC 14 for processing. ILEC 14processes (104) the pre-order request and then returns (106) a responsethat contains the requested information, an error message, or a query.The response from the ILEC 14 may be converted from EDI format to textfile format within transaction engine 36 or a different system,time-stamped, and forwarded to other systems of pseudo-CLEC 18 ifappropriate. Pseudo-CLEC 18 processes (108) the response. If complete,the pre-order information may be used to automatically or otherwisepopulate an order. However, as described above, not all orders are basedon pre-order information. If the pre-order response indicates an error,pseudo-CLEC 18 may modify the information and resubmit the pre-order toILEC 14 to begin the process anew. If an error message is received, ILECdocumentation and possibly support from its help desk 50 may be used tocorrect the error. The accuracy and timeliness of help desk support ispreferably recorded in connection with the POP Help Desk Support Testdescribed below. In one embodiment, pre-order transactions returningerror messages, or not returning any responses, are researched,corrected, and re-submitted until a correct response is ultimatelyreceived.

In general, the order and provisioning process allows CLEC 16 toinitiate and confirm delivery of particular services and serviceconditions. This process may or may not rely on information derived fromthe pre-order process. In an actual CLEC 16 environment, CLEC 16populates an order form using information collected from the CLEC'scustomer, from a pre-order response, or from any other suitable source,and submits the order to ILEC 14. In the testing environment, ordertransactions may be prepared (110) and submitted (112) to ILEC 14 usingtransaction engine 36. The transactions may be generated at transactionengine 36 in test file format, converted from text file format to EDIformat within transaction engine 36 or a different system, time-stamped,and forwarded to ILEC 14 for processing. ILEC 14 processes (114) theorder and returns (116) a response that contains a confirmation, errormessage, or query. The response from ILEC 14 may be converted from EDIformat to text file format within transaction engine 36 or a differentsystem, time-stamped, and then forwarded to other systems of pseudo-CLEC18 if appropriate. Pseudo-CLEC 18 processes (118) the response.

If the order contains all necessary information and is without error,ILEC 14 returns a confirmation to pseudo-CLEC 18 and then provisions(120) the requested services. If the order is incomplete or in error,ILEC 14 returns an error message. If the order response indicates anerror, pseudo-CLEC 18 may modify the information and resubmit the orderto ILEC 14, beginning the process anew. If an error message is received,ILEC documentation and possibly support from its help desk 50 may beused to correct the error. The accuracy and timeliness of such help desksupport is preferably recorded in connection with the POP Help DeskSupport Test described below. In one embodiment, orders returning errormessages, or not returning any responses, are researched, corrected, andre-submitted until a confirmation has been received. After provisioning,the ILEC 14 may return a completion notification to pseudo-CLEC 18 (sucha completion notification may not be expected for certain orders, suchas those involving planned cancellations).

In one embodiment, activities performed during this test may include,without limitation: (1) use test cases to develop transactions andtransaction content based on instructions provided in appropriatehandbooks; (2) submit transactions, logging the submittal date, time,and appropriate transaction information; (3) receive responses totransactions, logging receipt date, time, response type, and responsecondition (valid vs. reject); (4) submit and monitor manual orders ifrequired, logging submittal date, time, and suitable transactioninformation and logging receipt, date, time, response type, and responsecondition (valid vs. reject); (5) match the response to the originaltransaction verifying that the matching transaction can be found andrecording any mismatches; (6) verify response contains expected data andflag unexpected errors; (7) manually review unexpected errors,identifying and logging the error source and reason; (8) contact helpdesk for support as indicated in test cases and following theappropriate resolution procedures, logging response time, availabilityand other help desk behavior identified on help desk checklist; (9)correct expected errors, logging re-submittal date, time, andappropriate transaction information; (10) identify any transactions forwhich responses have not been received, record missing responses, andwhere multiple response are expected for a single transaction monitorreceipt of each response; (11) review status of pending orders,verifying and recording accuracy of response; (12) recognize and log anyjeopardy and delay notifications, logging any jeopardy or delaynotifications not received electronically; (13) perform joint testing,recording results using provisioning log and activity checklist; (14)perform joint provisioning, recording results using provisioning log andactivity checklist; (15) test completion on sampling of orders that havebeen provisioned, recording results in provisioning log and activitychecklist; (16) compare pseudo-CLEC metrics to ILEC retail metrics andreview ILEC measures corresponding to pseudo-CLEC 18; (17) comparepseudo-CLEC 18 to aggregate, identifying any variance in service levelsbetween pseudo-CLEC and live CLEC support; and (18) generate appropriatereports documenting and summarizing the test activities, results, andconclusions, including for example one or more of the reports describedabove in connection with the POP EDI Interface Certification Test.

In one embodiment, commencement of the test may be contingent upon allelements of a “Go/No Go” checklist being satisfied. These elements mayinclude, without limitation: (1) all documentation necessary to completetest cases has been received (e.g., product descriptions andavailability, business rules, flow-through list, interval guides, etc.);(2) EDI documentation needed to build transaction engine 36 and submitEDI transactions to EDI interface 30 has been received; (3) transactionengine 36 has been built and is operationally ready; (4) EDIconnectivity between transaction engine 36 and EDI interface 30 isestablished and EDI interface 30 has been tested and deemedsatisfactory; (5) ILEC 14 has provisioned the test bed; (6) selectionand description of test cases has occurred; (7) test case instances (thetest transactions) have been written; (8) a pseudo-CLEC help desk hasbeen established and help desk logs and databases are in place; and (9)a conference bridge with the ILEC 14 has been established, a contactlist has been created, and all suitable parties have been notified.

Test target areas and associated evaluation measures are summarized inthe tables below. Evaluation criteria for these measures may include, inany appropriate combination and without limitation: (1) the ILEC's EDIinterface 30 is consistently available during scheduled hours ofoperation for pre-orders; (2) ILEC 14 provides required pre-orderfunctionality; (3) ILEC 14 provides pre-order responses in agreed ontimeframe; (4) ILEC 14 provides accurate and complete pre-orderresponses; (5) ILEC 14 provides clear, accurate, and relevant pre-ordererror messages; (6) ILEC 14 provides timely pre-order error messages;(7) ILEC's EDI interface 30 is consistently available during scheduledhours of operation for orders; (8) the ILEC 14 provides required orderfunctionality; (9) the ILEC 14 provides confirmations in agreed ontimeframe; (10) ILEC 14 provides clear, accurate, and completeconfirmations; (11) provisioning dates identified in order confirmationare consistent with valid due date requests; (12) ILEC 14 provides errormessages in agreed upon timeframe; (13) the ILEC 14 provides clear,accurate, and complete error messages; (14) CLEC 16 has access topre-order and post-order information that is available to the ILEC'sretail representatives; (15) pre-order and order field names and fieldformats for address validation requests are compatible; (16) pre-orderand order field names and field formats for directory listings arecompatible; (17) the pre-order and order field names and field formatsfor product/service availability inquiries are compatible; (18)pre-order and order field names and field formats for duedate/appointment availability inquiries are compatible; and (19)pre-order and order field names and field formats for loop qualificationare compatible. The last columns of the tables indicate how particularevaluation criteria may, in one embodiment, correspond to the particularevaluation measures.

Test Target Areas and Measures—Pre-Order

Process Areas Sub-Process Areas Measures Criteria Submit Accessibilityof 1 pre-order interface transaction Create copy usable for Usability ofres- 25-29 subsequent processing sponse information Validate Sendaddress request using Presence of 2 address billing telephone numberfunctionality (TN) (BTN) Send address validation Presence of 2 requestusing working TN functionality (WTN) Send address validation Presence of2 request using WTN functionality Send integrated pre- Field name andfield 25  order/order transaction format compatibility Field format 25 compatibility Verify receipt of response Presence of 2 response Receive“match” message Timeliness of 3 response Accuracy and com- 4 pletenessof response Receive “near match” Timeliness of 3 response responseAccuracy and com- 4 pleteness of response Receive error messageTimeliness of 6 response Accuracy of 5 Response Clarity and com- 5pleteness of error message Retrieve Send CSR request using Presence of 2customer BTN functionality charge report (CSR) Send CSR request usingPresence of 2 WTN functionality Verify receipt of response Presence of 2response Receive “match” response Timeliness of 3 response Accuracy andcom- 4 pleteness of response Receive error message Timeliness of 6response Accuracy of 5 response Clarity and com- 5 pleteness of errormessage Request Send request for single Presence of 2 available TN(s)functionality TN(s) Send request for random Presence of 2 TN(s)functionality Send request for range of Presence of 2 specific TN(s)functionality Verify receipt of response Presence of 2 response Receiveavailable TN(s) Timeliness of 3 response response Accuracy and com- 4pleteness of response Receive error message Timeliness of 6 responseAccuracy of 5 response Clarity and com- 5 pleteness of error messageReserve Send reservation request for Presence of 2 TN(s) specific TNfunctionality Send reservation request for Presence of 2 single TNfunctionality Send reservation request for Presence of 2 multiple TNsfunctionality Verify receipt of response Presence of 2 response Receiveconfirmation Timeliness of 3 response Accuracy and com- 4 pleteness ofresponse Receive error message Timeliness of 6 response Accuracy of 5response Clarity and com- 5 pleteness of error message Cancel or Sendcancel or exchange Presence of 2 exchange TN reservation for single TNfunctionality reservation Send cancel or exchange Presence of 2 formultiple TNs functionality Verify receipt of response Presence of 2response Receive confirmation Timeliness of 3 response Accuracy and com-4 pleteness of response Receive error message Timeliness of 6 responseAccuracy of 5 response Clarity and com- 5 pleteness of error messageRequest See sub-processes for 2-6 available “Request Available TN(s)”DID number block(s) Reserve See sub-processes for 2-6 DID number“Reserve TN(s)” block(s) Cancel DID See sub-processes identified 2-6number for “Cancel TN block reservation” reservation Determine Sendservice availability Presence of 2 service and request functionalityfeature availability Determine PIC/LPIC Presence of 2 availabilityfunctionality Send Integrated pre- Field name 27  order/ordertransaction compatibility Field format 27  compatibility Verify receiptof response Presence of 2 response Receive availability Timeliness of 3response response Accuracy of 4 response Consistency with 14  retailcapability Receive error message Timeliness of 6 response Accuracy of 5response Clarity and com- 5 pleteness of error message Qualify Send loopqualification Presence of 2 loop inquiry functionality Send loopqualification Presence of 2 reservation functionality Send integratedpre- Field name 29  order/order transaction compatibility Field format29  compatibility Verify receipt of response Presence of 2 responseReceive qualification Timeliness of 3 response Accuracy and com- 4pleteness of response Consistency with 14  retail capability Receiveerror message Timeliness of 6 response Accuracy of 5 response Clarityand com- 5 pleteness of error message Determine Send request Presence of2 due date/ functionality appointment availability Send integrated pre-Field name 30  order/order transaction compatibitity Field format 30 compatibility Verify receipt of response Presence of 2 response Receivevalid response Timeliness of P5-3   response Accuracy and com- P5-4  pleteness of response Consistency with P5-14 retail capability Receiveerror response Timeliness of P5-6   response Accuracy of P5-5   responseClarity and com- P5-5   pleteness of error message Request Send ABCRrequest using Presence of 2, 4 access BTN functionality billing chargerecord (ABCR) Send ABCR request using Presence of 2, 4 WTN functionalitySend ABCR request for one Presence of 2, 4 or more particular sectionsfunctionality Verify receipt of response Presence of 2 response Receive“match” response Timeliness of 4 response Accuracy and com- 4 pletenessof response Receive error message Timeliness of 6 response Accuracy of 5response Clarity and com- 5 pleteness of error message Request Sendinstallation status Presence of 2 installation request functionalitystatus Verify receipt of response Presence of 2 response Receiveinstallation status Timeliness of 4 response Accuracy and com- 4pleteness of response Consistency with 14  retail capability Receiveerror message Timeliness of 6 response Accuracy of 5 response Clarityand com- 5 pleteness of error message Retrieve Send service order fromPresence of 2 service order order processor request functionality fromorder processor Verify receipt of response Presence of 2 responseReceive valid response Timeliness of 4 response Accuracy and com- 4pleteness of response Consistency with 14  retail capability Receiveerror message Timeliness of 5 response Accuracy of 5 Response Clarityand com- 5 pleteness of error message Retrieve Send directory listingPresence of 2 directory inquiry functionality listing Send integratedpre-order/ Field name 31  order transaction compatibility Field format31  compatibility Verify receipt of response Presence of 2 responseReceive directory listing Timeliness of 3 response Accuracy and com- 4pleteness of response Receive error message Timeliness of 6 responseClarity and com- 5 pleteness of error message

Test Target Areas and Measures—Order

Process Areas Sub-Process Areas Measures Criteria Submit Accessibilityof interface  7 order Send order transaction Presence of functionality 8 Send expedited order Presence of functionality  8 transaction Receiveacknowledg- Timeliness of response  9 ment of request Accuracy andcompleteness 10 of response Verify receipt of Presence of response 10,12 response Receive confirmation Timeliness of response  9 Accuracy andcompleteness 10-11 of response Receive error/reject Timeliness ofresponse 12 message Accuracy of response 13 Clarity and completeness 13of error message Receive acceptance of Timeliness of response  9expedited due date Accuracy and completeness 10 of response Receiverejection of Timeliness of response 12 expedited due date Accuracy andcompleteness 13 request of response Supple- Send supplement Presence offunctionality  8 ment order Receive acknowledge- Timeliness of response 9 ment of supplement Accuracy and completeness 10 of response Verifyreceipt of Presence of response 10-11 response Receive confirmationTimeliness of response  9 of supplement Accuracy of response Receiveerror reject Timeliness of response 12 message Accuracy of response 13Clarity and completeness 13 of error message View Inquire on completedPresence of functionality  8 completed order Consistency with retail 14order capability informa- tion

Transaction volumes may be increased, beyond normal levels, to test thecapacity of the ILEC's EDI interface 30 and identify potential “chokepoints” that might exist. Such stress testing is preferably performedduring off-peak periods to minimize the impact on the ILEC's liveproduction activities. Although the test is described as involvingprovisioning, certain transactions may be submitted in the “trainingmode” described above for the POP EDI Interface Certification Test. TheILEC 14 productions systems stop order transactions submitted in thetraining mode prior to the provisioning processes. In one embodiment,when the capacity of EDI interface 30 to handle peak and stresstransaction volumes is being tested, training mode is preferred tominimize the impact on the ILEC's downstream provisioning systems 46.

In one embodiment, to determine order transaction volumes for stresstesting, the testing entity observes one or more OSS access systems 20or other indicators of order activity to determine the highest hourlyorder volume (i.e. peak volume) as a percentage of total daily ordervolume. That percentage of the total daily volume is used as a baselinehourly volume for stress testing during a first test segment, such asduring the first hour of an example four hour test period. Anappropriate percentage increase over this baseline hourly volumeconstitutes a stress load. During a second test segment, such as duringthe second hour of the example four hour test period, transaction volumemay be progressively increased up to the specified stress load volume.This stress load volume may be maintained substantially constant for anyremaining test segments, such as the final two hours of the example fourhour test period. Although a particular volume variation is described,any constant or variable transaction volume may be used according toparticular needs. Moreover, although primarily described in connectionwith orders, such stress testing may be performed for pre-orders,orders, or any suitable combination of the two.

Test target areas and associated evaluation measures are summarized inthe tables below. In one embodiment, evaluation criteria used for normalvolume testing are not applicable to stress testing since the goal is togain insight into degradation of system performance as the transactionload is progressively increased from normal volume to stress volume.

Test Target Areas and Measures—Pre-Order & Order, Stress Volume

Process Area Sub-Process Area Measures Criteria Submit orders Receiveresponses Presence and timeliness of N/A response under stress volumeconditions

In one embodiment, after the completion notifications are received forcertain orders, tests are conducted to ensure that at least somecomponents of the ILEC 14 provisioning process were actually performed.For example, one or more test cases might be selected to verify that aninstallation, feature, or characteristic has been implemented correctly.Such tests may include physical observations made at ILEC COs ofcutovers in the field (“hot cuts”), testing lines, comparingpre-transaction and post-transaction switch output reports and monthlycustomer charge reports, directory listing and directory assistanceverification, test calling, or any other suitable test activities.Testing related to the ILEC's provisioning of orders may be performed inconnection with the POP Provisioning Parity and ProvisioningCoordination Tests described more fully below.

Test target areas and associated evaluation measures are summarized inthe table below. Evaluation criteria for these measures may include, inany appropriate combination, without limitation: (1) ILEC 14 providescompletion notifications in a timely manner; (2) ILEC 14 providesaccurate and complete completion notifications; (3) ILEC 14 performsprovisioning activities according to timeframes identified onconfirmation; (4) CSRs are properly updated after completion of order;(5) directory listings and directory assistance are updated according toorder specifications; (6) switch output reports reflect featuresexpected after completion of order; (7) ILEC personnel adhere topolicies and procedures when performing CO cross connects and cutovers;(8) calls made to numbers ordered with intercept feature receiveintercept recording giving new number; (9) calls made to disconnectedorders go to a vacant code announcement; and (10) the ILEC 14 providestimely jeopardy/delay notices in compliance with its establishedjeopardy procedures. The last column of the table indicates howparticular evaluation criteria may, in one embodiment, correspond to theparticular evaluation measures.

Test Target Areas and Measures—Provisioning

Process Sub- Areas Process Areas Measures Criteria Receive ReceiveTimeliness of response 1, 3 completion completion Timeliness of dates2-3 notification notification Accuracy of data  2 Match responseAccuracy of provisioning 4-9 to order transac- tion and con- firmationVerify receipt Completion notification 1-2 of completion received forall transactions notification Receive Receive jeopardy Timeliness ofnotification 10 jeopardy notification Timeliness of dates 10notification Accuracy of data 10 Frequency of notification 10 Identifyreason Accuracy of response 10 for jeopardy Monitor follow- Timelinessof closure 10 up activities Compliance with procedures 10 ReceiveReceive delay Timeliness of response delay notification Timeliness ofdates 10 nofification Accuracy of data 10 Frequency of data 10 Matchresponse Accuracy of response 10 to transaction Identify reason Accuracyof response 10 for delay Follow up Contact Timeliness of answer 10 ondelayed provisioning Availability of support 10 provisioning help deskactivities Request status Accuracy of response 10 of response orCompleteness of response 10 delay Timeliness of response 10 Escalaterequest Accuracy and completeness 10 for information of proceduresCompliance to procedures 10 Escalate request Accuracy and completeness10 for provisioning of procedures Compliance to procedures 10 Monitor toTimeliness of closure 10 closure Compliance to procedures 10

The testing entity evaluates ILEC 14, according to these or otherevaluation criteria, and preferably categorizes test results by servicefamily (e.g., POTS, ISDN, Centrex), service delivery method (e.g.,resale, UNE-P, UNE-L), whether submitted transactions were flow through(as is described below in connection with the POP Order Flow ThroughTest), whether transactions were submitted in live or training mode, orin any other suitable manner, in any combination.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

C. POP GUI Interface Functional Test

This test is designed to provide a comprehensive review of elementswithin the POP Domain, as delivered through the ILEC's web-based orother GUI interface 32, and performance of the GUI interface 32. Thetest involves transactions that are manually entered using the GUI 38 ofpseudo-CLEC 18. In one embodiment, for example, the GUI interface 32includes one or more web servers that communicate HTML pages or otherweb-based files over the Internet to a web browser associated with GUI38. The test transactions may include any suitable mix of pre-orders andorders, and preferably provide an end-to-end view of POP processes.

CLECs 16 typically order most services from an ILEC 14 using order formssuch as LSRs, which automated interfaces such as EDI interface 30 areequipped to handle. However, some types of complex services (e.g.,interoffice facilities) cannot usually be ordered using LSRs, insteadrequiring a different type of order form such as an Access ServiceRequest (ASR). CLECs 16 may submit such orders to ILEC 14 using GUI 38and GUI interface 32. In one embodiment, although the expectation willbe that EDI interface 30 is the primary method of submittingtransactions in a competitive environment, a CLEC 16 may be expected touse the GUI interface 32 when CLEC 16 is in a start-up mode and providessmall transaction volumes or for more complex services requiring ASRs orthe like. If attempts to use GUI interface 32 are unsuccessful (as forunsuccessful attempts to use EDI interface 30), CLEC 16 may submitorders manually to manual interface 34, as described more fully below inconnection with the POP Manual Order Process Test.

As with the POP EDI Interface Functional Test described above,transaction test cases for this test should preferably span a variety ofbusiness and residential customer needs, a variety of service families(e.g., POTS, ISDN, and Centrex), and a variety of service deliverymethods (e.g., resale, UNE-P, and UNE-L). Test cases used for the testmay include a suitable subset of the test cases used during the POP EDIInterface Functional Test or any other suitable test cases. In oneembodiment, test scenarios used to derive the test cases may include,without limitation, scenarios 1-7, 8-34, 36-38, 45-46, 49-51, 57-58, 62,64-66, 91-93, 103-105, 107, 116, 118-127, 130 and 130 listed in AppendixA. Additional scenarios may be used to validate certain flow throughcapabilities. If GUI interface 32 is not expected to be used for largetransaction volumes in the near future, stress testing of GUI interface32 may not be warranted.

As described above, ILEC 14 provides test bed accounts against whichpre-order and order transactions may be placed. For testing, variouspre-order and order transactions are created using GUI 38, based on anappropriate test bed account, and submitted to GUI interface 32 forhandling. For each pre-order request submitted, the expected result is aresponse from ILEC 14 containing the requested information. Responsesmay need to be sought out by the pseudo-CLEC 18, by requesting web pagescontaining response information for example, rather than simply waitingfor responses to arrive from the ILEC 14 as in the POP EDI InterfaceFunctional Test. Where actual responses are not actively sent topseudo-CLEC 18, ILEC 14 may provide pseudo-CLEC 18 with notificationthat responses are available for access. Error correction andtransaction re-submission may occur substantially as described above forthe POP EDI Interface Functional Test, numerous cycles perhaps beingneeded for successful order confirmation. The testing entity maydetermine whether the transactions flow through without humanintervention, as described more fully below in connection with the POPOrder Flow Through Test, as may evaluate ILEC provisioning of orders asis described more fully above in connection with the POP EDI FunctionalTest.

Test target areas and associated evaluation measures are summarized inthe tables below. Evaluation criteria for these measures may include, inany appropriate combination and without limitation: (1) the GUIpre-order capability is consistently available during scheduled hours ofoperation, (2) ILEC 14 provides necessary pre-order functionality, (3)the ILEC 14 provides pre-order responses in an agreed upon timeframe,(4) the ILEC 14 provides accurate and complete pre-order responses, (5)ILEC 14 provides clear, accurate, and relevant pre-order error messages,(6) ILEC 14 provides timely pre-order error messages, (7) the GUI ordercapability is consistently available during scheduled hours ofoperation, (8) ILEC 14 provides required GUI order functionality, (9)the ILEC 14 provides accurate and complete order responses, (10) ILEC 14provides timely order responses, (11) ILEC 14 provides accurate andrelevant order error messages, (12) ILEC 14 provides timely order errormessages, (13) provisioning dates identified within the ILEC's orderconfirmation are consistent with valid due date request, (14) ILEC 14performs provisioning activities according to timeframes identified onits confirmations, (15) ILEC 14 provides jeopardy/delay notices whenappropriate in a timely manner in compliance with established jeopardyprocedures, and (16) ILEC 14 is capable of supporting “ASR-like” orderssubmitted using GUI 38. The last columns of these tables indicates howparticular evaluation criteria may, in one embodiment, correspond toparticular evaluation measures.

Test Target Area and Measures—Pre-Order

Process Areas Sub-Process Areas Measures Criteria Submit Accessibilityof interface 1 pre- order trans- action Send address request usingPresence of functionality 2 BTN Send address validation Presence offunctionality 2 request using WTN Send address validation Presence offunctionality 2 request using address Verify receipt of responsePresence of response 4 Receive “match” response Timeliness 3 Accuracyand 4 completeness Receive error message Timeliness 6 Accuracy 5 Clarityand completeness 5 Retrieve Send CR request Presence of functionality 2CR using BTN Send CR request using Presence of functionality 2 WTNVerify receipt of response Presence of response 4 Receive “match”response Timeliness 3 Accuracy and 4 completeness Receive error messageTimeliness 3 Accuracy 4 Clarity and completeness 5 Request Send requestfor specific Presence of functionality 2 avail- TN(s) able TN(s) Sendrequest for random Presence of functionality 2 TN(s) Send request forrange of Presence of functionality 2 specific TNs Verify receipt ofresponse Presence of response 2 Receive available numbers Timeliness 3response Accuracy and 4 completeness Receive error message Timeliness 6Accuracy 5 Clarity and completeness 5 Reserve Send reservation requestfor Presence of functionality 2 TN(s) specific TN(s) Send reservationrequest for Presence of functionality 2 single TN Send reservationrequest for Presence of functionality 2 multiple TNs Verify receipt ofresponse Presence of response 4 Receive confirmation Timeliness 3Accuracy and 4 completeness Receive error message Timeliness 6 Accuracy5 Clarity and completeness 5 Cancel Send cancel or exchange Presence offunctionality 2 or ex- reservation for single TN change TN res- ervationSend cancel or exchange Presence of functionality 2 for multiple TNsVerify receipt of response Presence of response 4 Receive confirmationTimeliness 3 Accuracy and 5 completeness Receive error messageTimeliness 6 Accuracy 5 Clarity and completeness 5 Deter- Send serviceavailability Presence of functionality 2 mine request service andfeature avail- ability Determine PIC/LPIC Presence of functionality 2availability Verify receipt of response Presence of response 4 Receiveavailability Timeliness 3 response Accuracy 4 Consistency with retail13  capability Receive error message Timeliness 6 Accuracy 5 Clarity andcompleteness 5 Qualify Send loop qualification Presence of functionality2 loop inquiry Send loop qualification Presence of functionality 2reservation Verify receipt of response Presence of response 4 Receivequalification Timeliness 3 Accuracy and 4 completeness Consistency withretail 13  capability Receive error response Timeliness 6 Accuracy 5Clarity and completeness 5 Deter- Send request Presence of functionality2 mine due date/ appoint- ment avail- ability Verify receipt of responsePresence of response 4 Receive valid message Timeliness 3 Accuracy and 4completeness Consistency with retail 13 capability Receive error messageTimeliness 6 Accuracy 5 Clarity and completeness 5 Request Sendinstallation status Presence of functionality 2 install- request ationstatus Verify receipt of response Presence of response 4 Receiveinstallation status Timeliness 3 Accuracy and 4 completeness Consistencywith retail 13 capability Receive error message Timeliness 6 Accuracy 5Clarity and completeness 5 Retrieve Send service order from Presence offunctionality 2 service order processor request order from order proces-sor Verify receipt of response Presence of response 4 Receive validresponse Timeliness 3 Accuracy and 4 completeness Consistency withretail I 3 capability Receive error message Timeliness 6 Accuracy 5Clarity and completeness 5 Retrieve Send directory listing Presence offunctionality 2 direc- inquiry tory Verify receipt of response Presenceof response 4 listing Receive directory listing Timeliness 3 Accuracyand 4 completeness Receive error Timeliness 6 Accuracy 5 Clarity andcompleteness 5

Test Target Areas and Measures—Order

Process Cri- Areas Sub-Process Areas Measures teria Submit Accessibilityof interface 7 order Send order transaction Presence of functionality 8Send expedited order Presence of functionality 8 transaction Verifyreceipt of response Presence of response 10 Receive confirmationTimeliness 9 Accuracy and completeness 10 Receive error/rejectTimeliness 12 message Accuracy 11 Clarity and completeness 11 Receiveacceptance of Timeliness 9 expedited due date Accuracy and completeness10 Receive rejection of Timeliness 13 expedited due date requestAccuracy and completeness 11 Supple- Send supplement Presence offunctionality 7 ment Verify receipt of response Presence of response 10order Receive confirmation Timeliness 9 Accuracy 10 Receive error/rejectTimeliness 13 message Accuracy 11 Clarity and completeness 11 ViewInquire on completed order Presence of functionality 8 com- Consistencywith retail 13 pleted capability order infor- mation

Test Target Areas and Measures—Provisioning

Process Cri- Areas Sub-Process Areas Measures teria Receive Receivecircuit layout Timeliness of response 10 design Timeliness of dates 17docu- Accuracy of data 11 ments Receive design Layout Timeliness ofresponse 10 Timeliness of dates 17 Accuracy of data 11 Verify receipt ofresponse Response received for all transactions Receive transactionAccuracy and completeness 11 response of response Determine status ofAccuracy and completeness 9 transaction response of capability ReceiveReceive completion Timeliness of response 10 comple- notificationTimeliness of dates 17 tion Accuracy of data 11 notifi- cation Matchresponse to order Accuracy of provisioning 11 transaction andconfirmation Verify receipt of com- Completion notification 11 pletionnotification received for all transactions Receive Receive jeopardyTimeliness of notification 20 jeopar- notification Timeliness of dates17 dy noti- Accuracy of data 11 fication Frequency of notification 20Identify reason for jeopardy Accuracy of response 11 Monitor follow-upactivities Timeliness of closure 18 Compliance with 10 proceduresReceive Receive delay notification Timeliness of response 20 delayTimeliness of dates 11 notifi- Accuracy of data 11 cation Frequency ofdelay 20 Match response to Accuracy of response 11 transaction Identifyreason for delay Accuracy of response 11 Follow Contact provisioninghelp Timeliness of answer 18 up on desk Availability of support 17delayed provi- sioning activi- ties Request status of response Accuracyof response 18 or delay Completeness of response 18 Timeliness ofresponse 20 Escalate request for Accuracy and completeness 15information of procedures Compliance to procedures Escalate request forAccuracy and completeness 15 provisioning of procedures Compliance toprocedures 16 Monitor to closure Timeliness of closure 18 Compliance toprocedures 16

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

D. POP Order Flow Through Test

This test evaluates the ability of orders to “flow” from CLECs 16through the ILEC's order processor 44 without human intervention. In oneembodiment, flow through orders may pass through EDI interface 30, GUIinterface 32, or both. The test is preferably executed in connectionwith one or more of the POP EDI Interface Certification, EDI InterfaceFunctional, and GUI Interface Functional Tests described above. Oncesubmitted, the orders are monitored to identify orders requiring manualhandling within the ILEC's manual interface 34 or otherwise. Testtransactions are preferably generated with a unique PON having a flowthrough indicator to facilitate data collection and analysis. Receivinga confirmation from the ILEC 14 indicates successful flow through.

In one embodiment, testing of the ILEC's flow through capabilitiesincludes the following tasks: (1) identifying tests cases eligible forflow through testing; (2) developing a log to track whether ordersflowed through; (3) submitting transactions using transaction engine 36and EDI interface 30, GUI 38 and GUI interface 32, or both as describedabove, logging the submittal date, time, and appropriate transactioninformation; (4) receiving transaction responses, logging receipt date,time, response transaction, and response condition (valid vs. reject);(5) identifying and recording which orders flowed through without manualintervention; (6) identifying, recording, and analyzing the reasonsmanual handling was required and, if caused by an error, identifying theerror source and reason; (7) correct pseudo-CLEC errors, re-submit, andverify that re-submitted orders flow through (ILEC errors are notcorrected); (8) identifying, recording, and analyzing the reasons forany missing responses; and (9) generating appropriate reports.

Preferably, only flow through eligible orders as specified by ILEC 14are tested (including any supplements or cancels considered by the ILEC14 to be flow through). Subject to any such restriction, the test mayuse any of the test cases used for the POP EDI Interface Functional andGUI Interface Functional Tests described above. In a particularembodiment, test cases for this test are derived from scenarios 1-2,5-6, 8, 11, 13-14, 16-17, 23-24, 27, 31, 33-37, 45, 65, 92, 94, 96-97,102, 105, 118-119, 127, 129, and 131 listed in Appendix A. It may bedesirable to introduce planned errors that should result in automaticerror/reject transactions. Preferably, any such planned errors will notbe corrected and re-submitted.

Test target areas and associated evaluation measures are summarized inthe table below. Evaluation criteria for these measures may include, inany appropriate combination and without limitation: (1) ILEC resaleorders that are known to be flow through do fully flow through, (2) ILECUNE-P orders that are known to be flow through do fully flow through,(3) ILEC UNE-L orders that are known to be flow through do fully flowthrough, and (4) confirmations are received within two hours for ordersthat fully flow through. The last column of the table indicates how theparticular evaluation criteria may, in one embodiment, correspond to theparticular evaluation measures.

Test Target Areas and Measures Process Area Sub-Process Area MeasureCriteria Submit order Determine if order should Applicability as flowthrough 1-4 flow through in pre-filing agreement and in existing systemSubmit order to EDI Accessibility of interface 7 from interface Test BSubmit order to GUI Accessibility of interface 8 from interface Test CMonitor order Identify orders that did flow Compliance with flow through1-4 through standards Identify orders that did not Clarity of manualsteps 1-5, 1 flow through from Test F Verify all orders wereCompleteness of order 1-4 processed processing

Flow through performance will preferably be evaluated at both normal andstress volumes. Test results may be categorized according to theassociated test in which the results were generated. For example, testresults for flow through testing performed in connection with the POPEDI Transaction Interface Functional Test at normal volume may bepresented separate from results for testing performed at stress volumeor testing performed in connection with the POP GUI Functional Test.Test results may include, without limitation: (1) the percentage andnumber of orders that flowed through, by order type, service type,and/or service delivery method; (2) the percentage and number of ordersthat did not flow through, by order type, service type, service deliverymethod, and/or reason code; (3) actual results versus expected results;and (4) actual results versus standards defined in any agreements.

In one embodiment, the test may incorporate “Achieved,” “Commercial,”and “Parity” test components. The activities described above may beperformed for the Achieved component.

For the Commercial component, the testing entity will evaluate the“actual” order flow through process for a sample of CLEC orders, forexample, UNE orders. Pseudo-CLEC orders are not included in this sample.A thorough review of order flow through data from the authentic CLECorders should allow the testing entity to determine the actual flowthrough rates for the selected sample. The testing entity may alsoidentify and document the cause of any orders falling out such thatmanual intervention is required. Specific activities for this componentmay include, without limitation: (1) solicit CLEC volunteers to providesubmitted orders; (2) coordinate with ILEC to set up tracking reports onidentified CLEC orders (e.g., by CLEC and PON); (3) receive orders andrelated responses from the participating CLECs 16; (4) determine whichorders flowed through; (5) request corresponding orders from the ILEC14, along with error messages for orders that fell out for manualhandling; (6) determine error source and reason for orders that did notflow; and (7) document findings and prepare report. The Commercialcomponent may serve as a control for the Achieved component and mayenhance the blindness of test results.

For the Parity component, ILEC 14 will identify retail orders analogousto certain test scenarios, evaluate the level of parity between theretail orders and the orders based on these test scenarios, and generatea report. The testing entity will then review the ILEC's report andcomment on its validity. Specific activities may include, withoutlimitation: (1) establish appropriate parameters for ILEC retail vs.wholesale flow through eligibility report; (2) observe actual ILECretail process; (3) receive and review the ILEC parity report; and (4)document findings and prepare report. The Commercial component, Paritycomponent, or both may be performed instead of in addition to theAchieved component according to particular needs and available testingresources.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

E. POP Live CLEC Functional Test

In one embodiment, as part of its functional evaluation of the POPDomain, the testing entity seeks qualitative input and quantitative dataon the “real world” experience of CLECs 16 operating in the ILEC'scalling area. For certain types of transactions, involvement is soughtfrom CLECs 16 that are willing to participate in live transactiontesting. In some cases, where statistically relevant data is impossibleor impractical to collect from one or more CLECs 16 for example, thetesting entity may conduct focused interviews with CLEC 16 personnel tomore fully capture the CLEC's 16 experiences with the ILEC's OSSs 12 andassociated processes for the POP Domain and more fully evaluate anyparity issues that may exist. CLECs 16 willing to participate in thisaspect of the test are interviewed and their experiences relating to POPDomain activities incorporated into the test results, preferably aftersuitable validation by the testing entity.

Live CLEC testing may provide an important alternative for complexorders that may not be readily or adequately simulated in the regulartesting environment. Examples may include complex facilities-basedorders and orders, such as those for UNE-L with Local Number Portability(LNP), that require a coordinated cutover on an actual CLEC switch(typically within a collocation cage at an ILEC CO) to fully complete.It is also valuable to track ILEC performance in a real worldenvironment to help control against bias in the results. The testingentity preferably asks CLECs 16 for data concerning live transactionsthat substantially replicate those submitted during the POP EDIInterface Functional and GUI Interface Functional Tests. This live datacan be used to further validate, or possibly invalidate, data collectedduring such tests.

An attempt should be made to identify CLECs 16 that order a wide varietyof products to ensure that the full range of service types and servicedelivery methods offered by ILEC 14 are tested. The testing entity maywork with the CLECs 16 to choose specific transactions that best meetthe objectives described above and are considered the most important toCLECs 16. The testing entity may review internal CLEC processes, observelive CLEC transactions, review CLEC measurements for such transactions(such as in confirmation logs, help desk logs, jeopardy notice logs,completion logs, or other documentation), and perform any other suitableactivities designed to aid its evaluation of ILEC 14 performance. Tocapture a more complete set of metrics, where appropriate the testingentity may suggest that CLECs 16 make alternative or additionalmeasurements of the ILEC's performance. Once the testing entitydetermines that appropriate and accurate measurements have been made,both recent historical and current data for the measurements isincorporated into the test data to be analyzed.

In one embodiment, the following activities are performed during thecourse of this test, without limitation: (1) solicit one or more CLECs16 for live orders to support a selection of test cases; (2) record CLECsubmissions for testing; (3) verify accuracy of CLEC gauges; (4) matchsubmissions to selected test scenarios and test cases; (5) selectsubmissions that will be included in live test; (6) identify scenariosand test cases for which live CLEC input was not received and determinehow those scenarios and test cases are to be tested; (7) establishmonitoring schedule for live CLEC orders; (8) monitor submission of liveCLEC orders; (9) monitor transaction responses, for example, loggingreceipt date, time, transaction type, and condition (valid vs. reject)for the responses; (10) verify transaction responses contain expecteddata and record any errors; (11) manually review errors, identify errorsources, and identify and log reasons for errors; (12) monitor contactsto help desk 50 as needed for errors and non-error related assistance,logging response time, availability, and other behavior as identified ona help-desk checklist; (13) log re-submission of any transactions afterany errors have been corrected; (14) identify any transactions for whichresponses have not been received and record the missing responses; (15)log any jeopardy or delay notifications; (16) monitor order status,monitor provisioning activities, and complete a provisioning checklist;(17) generate appropriate reports; and (18) compare CLEC metrics to ILECmetrics for the test cases. Outputs for the test may include, withoutlimitation, completed review of CLEC POP experiences, completed cutovertests executed in coordination with CLECs 16, completed review of anyother CLEC cutover data and observations, completed review of the ILEC'sconfirmations to CLEC orders, completed review of CLEC collocationorders, and completed review of CLEC interface development activities.

Test target areas and associated evaluation measures are summarized inthe table below. Evaluation criteria for these measures may include, inany appropriate combination and without limitation: (1) ILEC 14 haswell-defined, documented, and understandable process for establishingmanual transaction capabilities with CLECs 16; (2) the ILEC 14 has awell-defined, documented, and understandable process for establishingGUI transaction capabilities with CLECs 16; (3) ILEC 14 has awell-defined, documented, and understandable process for establishingEDI transaction capabilities with CLECs 16; (4) manual interface 34 isconsistently available during scheduled hours of operation; (5) GUIinterface 32 is consistently available during scheduled hours ofoperation; (6) EDI interface 30 is consistently available duringscheduled hours of operation; (7) the GUI interface 32 provides CLECs 16sufficient functionality to perform transaction set; (8) documentationsupplied by ILEC 14 is sufficient to create transactions; (9) the ILEC14 provides the required transaction functionality; (10) ILEC 14provides response in agreed upon timeframe; (11) ILEC 14 providesaccurate response; (12) ILEC 14 provides clear, accurate and relevanterror messages; (13) data elements comprising transaction requests orresponses are usable for subsequent processing; (14) the ILEC'swholesale service to CLECs 16 is consistent with its service to itsretail organization; (15) help desk is accessible and responsive duringscheduled hours of operation; (16) help desk provides meaningful orderentry technical support to CLEC order entry questions; (17) ILEC 14provides well-defined and documented escalation procedures; (18) ILEC 14complies with its own escalation procedures; (19) the ILEC 14 providesorder confirmation in required timeframe; (20) the ILEC 14 commits toprovisioning dates identified in valid date requests; (21) the ILEC 14performs provisioning activities according to timeframes identified onits order confirmation; (22) during any joint planning and coordinationactivities, ILEC 14 provides knowledgeable and capable personnel tosupport CLECs 16; (23) ILEC 14 consistently performs coordinatedprovisioning preparation work in timely and effective manner; (24) ILEC14 provides jeopardy notices when they are appropriate in a timelymanner in compliance with established procedures; (25) the ILEC 14provides delay notices when appropriate in a timely manner in compliancewith established procedures; (26) ILEC 14 provides completion notices ina timely manner in compliance with established procedures; (27) ILEC 14provides clear and comprehensive procedures for ordering/provisioningactivities which are complex or have an extended timeline; (28) the ILEC14 provides knowledgeable and capable personnel to support CLECs 16 withrespect to the ordering/provisioning activities which are complex orhave an extended timeline; and (29) ILEC 14 complies with its ownprocedures in providing services to CLECs 16 involvingordering/provisioning activities which are complex or have an extendedtimeline. The last column of the table indicates how certain evaluationcriteria may correspond to certain evaluation measures in a particularembodiment.

Test Target Areas and Measures - Pre-Order Process Areas Sub-ProcessAreas Measures Criteria Validate address Create address validationClarity, accuracy, and 1-3, 5-6, request transaction completeness of 8documentation Accessibility of interface Send address request usingAccuracy and completeness of 5-7, 9 WTN functionality Send addressvalidation Accessibility of interface 5-7, 9 request using addressAccuracy and completeness of funtionality Receive “near match”Timeliness, accuracy, and 10-11 response completeness Receive “no match”Timeliness and accuracy 10-11, 13 response Receive error messageTimeliness, accuracy, clarity, 10-13 and completeness Match response toAccuracy of response 11 validation request Correct errors Clarity,accuracy, and 12, 15-16 completeness of documentation Accuracy andcompleteness of help desk information Determine status of inquiryAccuracy and completeness of 9 capability Create copy usable forAccuracy and completeness of 11, 13-14 subsequent processing informationprovided Usability of information Consistency with retail capabilityRetrieve CR Determine type of inquiry to Clarity, accuracy, and 1-3 send(CSIQ or CTIQ) completeness of documentation Create CR request Clarity,accuracy, and 1-3, 5, 8 transaction completeness of documentationAccessibility of interface Send CR request using Accessibility ofinterface 5-7, 9 WTN Accuracy and completeness of functionality Receive“match” response Timeliness and accuracy 10-11, 13 Receive “no match”Timeliness and accuracy 10-11, 13 response Receive error messageTimeliness, accuracy, clarity, 10-13 and completeness Match response toAccuracy of response 11 validation request Correct errors Clarity,accuracy, and 12 completeness of documentation Accuracy and completenessof 15-16 help desk information Determine status of inquiry Availabilityof capability 5-6 Create copy of information Accuracy and completenessof 8, 14 usable for subsequent information provided processing Usabilityof information Consistency with retail capability Determine due date/Create due date appointment Clarity, accuracy, and 1-3 appointmentavailability request completeness of availability transactiondocumentation Send request Accessibility of interface 5-7 Accuracy andcompleteness of functionality Receive valid response Timeliness,accuracy, clarity, 10-12 and completeness Match response to Accuracy ofresponse 11 validation request Correct errors Clarity, accuracy, and 12,15-16 completeness of documentation Accuracy and completeness of helpdesk information Resubmit available due date Accessibility of interface5-6 request Verify response received Accuracy and completeness of 11response Determine status of inquiry Accuracy and completeness of 9capability Reserve due date/ Create due date/ Clarity, accuracy and 1-3appointment appointment reservation completeness of request transactiondocumentation Send request Accessibility of interface 7 Accuracy andcompleteness of functionality Receive valid response Timeliness,accuracy, and 10-11, 14 completeness Consistency with retail capabilityReceive error message Timeliness, accuracy, clarity, 10-12 andcompleteness Match response to Accuracy of response 11 validationrequest Correct errors Ciarity, accuracy, and 12, 15-16 completeness ofdocumentation Accuracy and complete of help desk information Follow upon delayed Contact pre-ordering help Timeliness of answer 10, 15pre-order activities desk Availability of support Request status ofresponse Timeliness, accuracy, and 11, 16 completeness of responseEscalate request for Accuracy and completeness of 18-19 informationprocedures Compliance to procedures Request pre-order Contactappropriate help Timeliness of answer 10, 15 transaction population deskAvailability of support support Ask question Timeliness, accuracy, and10-11, completeness of response 15-16 Request pre-order error Contactappropriate help Timeliness of answer 10, 15 correction support deskAvailability of support Ask question Timeliness, accuracy, and 11, 16completeness of response

Test Target Areas and Measures - Order Process Areas Sub-Process AreasMeasures Criteria Submit Order Determine type of order to Clarity andaccuracy of 1-3, 28 create documentation Create order transaction(s)Clarity, accuracy, and 1-3 completeness of documentation Send order inLSR format Accessibility of Interface 4-6 Send order in ASR formatAccessibility of Interface 4-6 Receive acknowledgment of Timeliness andaccuracy, 10-11 valid request (LSR) Receive acknowledgment of Timelinessand accuracy 10-11 valid request (ASR) Match response to Accuracy ofresponse 11 transaction Receive error/reject Timeliness, accuracy,clarity, 10-12 message and completeness Correct errors Clarity,accuracy, and 12, 15-16 completeness of documentation Accuracy andcompleteness of help desk information Re-submit order Accessibility ofInterface 4-6 Verify response receive Accuracy and completeness of 11response Determine status of Accuracy and completeness of 9 transactionresponse capability Supplement order Create supplement Clarity,accuracy, and 1-3 transaction(s) completeness of documentation Sendsupplement Accessibility of Interface 4-6 Receive confirmation ofTimeliness and accuracy 10-11 receipt Match response to Accuracy ofresponse 11 transaction Receive error/reject Timeliness, accuracy,clarity, 10-12 message and completeness Correct errors Clarity,accuracy, and 12, 15-16 completeness of documentation Accuracy andcompleteness of help desk informatlon Re-submit supplement Accessibilityof interface 4-6 Determine status of Accuracy and completeness of 9transaction response capability Verify response received Accuracy andcompleteness of 11 capability Determine status of Accuracy andcompleteness of 9 transaction response capability Cancel order Createcancel transaction Clarity, accuracy, and 1-3 completeness ofdocumentation Send cancel Accessibility of interface 4-6 Receiveconfirmation Timeliness and accuracy 10-11 Match response to Accuracy ofresponse 11 transaction Receive error/reject Timeliness, accuracy,clarity, 10-12 message and completeness Verify response receivedAccuracy and completeness of 11, 13 response Determine status ofAccuracy and completeness of 9 transaction response capability Expediteorder Request expedited due date Clarity, accuracy, and 1-3 completenessof documentation Receive acceptance of Timeliness and accuracy 10-11expedited due date Receive rejection of Timeliness and accuracy 10-11expedited due date request Request order status Create order statusClarity, accuracy, and 1-3 transaction completeness of documentationSubmit order status Accessibility of interface 6, 9 transaction Accuracyand completeness of capability Receive current status Timeliness andaccuracy 10-11 View completed order Inquire on completed order Accuracyand completeness of 9, 14 information functionality Consistency withretail capability Follow up on delayed Contact ordering help deskTimeliness of answer 15-16 order activities Availability of supportRequest status of response Timeliness, accuracy, and 10-11 completenessEscalate request for Accuracy and completeness of 18-19 informationprocedures Compliance to procedures Monitor closure of requestCompleteness and accuracy of  9-10 follow-up Timeliness of answerRequest order Contact appropriate help Timeliness of answer 15population support desk Availability of support Ask question Timeliness,accuracy, and 10-11, 17 completeness Request order error Contactappropriate help Timeliness of answer 15-16 correction support deskAvailability of support Ask question Timeliness, accuracy, and 10-11, 17completeness

Test Target Areas and Measures -- Provisioning Process Areas Sub-ProcessAreas Measures Criteria Receive order Receive LSR confirmationTimeliness of response 20-21 confirmation Timeliness of dates Accuracyof data Receive ASR commitment Timeliness of response 20-21 Timelinessof dates Accuracy of data Match response to Accuracy of response 11transaction Receive error/reject Timeliness and accuracy of 12, 20message after original response confirmation Accuracy and completenessof error message Applicability of order flow- through Correct errorsClarity, accuracy, and 16 completeness of documentation Accuracy andcompleteness of help desk information Re-submit order Accessibility ofinterface 4-6 Verify response received Accuracy and completeness of 9response Determine status of Accuracy and completeness of 11 transactionresponse capability Receive design Receive circuit layout Timeliness ofresponse 10-11 documents (CLR) Timeliness of dates Accuracy of dataReceive design layout Timeliness of response 10-11 (DLR) Timeliness ofdates Accuracy of data Match response to Accuracy of response 9transaction Verify response received Accuracy and completeness of 9response Determine status of Accuracy and completeness of 11 transactionresponse capability Receive completion Receive completion Timeliness ofresponse 27 notification notification transaction Timeliness of datesAccuracy of data Match response to Accuracy of response 11 transactionVerify response received Accuracy and completeness of 11 responseDetermine status of Accuracy and completeness of 9 transaction responsecapability Test service Accuracy of provisioning 24 Receive delayReceive delay notification Timeliness of response 26 notificationtransaction Timeliness of dates Accuracy of data Frequency of delayMatch response to Accuracy of response 11 transaction Identify reasonfor delay Accuracy of response 11 Follow up on delayed Contactprovisioning help Timeliness of answer 15, 29 provisioning activitiesdesk Availability of support Request status of response Timeliness,accuracy, and 11, 29 or delay completeness Escalate request for Accuracyand completeness of 18-19, 30 information procedures Compliance toprocedures Escalate request for Accuracy and completeness of 19, 30provisioning procedures Compliance to procedures Monitor to closureTimeliness of closure 26, 30 Compliance to procedures

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

F. POP Manual Order Process Test

This test is designed to evaluate the manual order handling processes ofILEC 14. These processes are implemented within the manual interface 34,which may be associated in an ILEC operations center. The test involvesstructured interviews with ILEC personnel involving questions tailoredto the evaluation criteria, structured walk throughs for directobservation of ILEC personnel, and documentation review to evaluatewhether the ILEC's processes provide a framework for the efficientreceipt, review, and execution of manual orders. The test involves aprocedural evaluation of the ILEC's established processes for handlingmanual orders. Actual performance of manual order operations may betested in one or more POP Domain functional tests. In one embodiment,the test is conducted in connection with the POP EDI Interface and GUIInterface Functional Tests described above. Orders are submittedmanually if a test scenario calls for an order type that cannot besubmitted electronically or the electronic submission of an order failsfor some reason.

In one embodiment, test target areas for this test include such thingsas the receiving of manual orders, processing of manual orders(including entry into SOP), status tracking and reporting, problemescalation, capacity management and planning, and process management andimprovement. Evaluation criteria relating to these test target areasinclude such things as the accuracy and completeness of manual orderlogs; the completeness and consistency of manual order processes, orderreporting and tracking processes, and problem escalation processes; andthe completeness and consistency of operating management practices(including controllability, efficiency, and reliability of managementprocesses).

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how particularevaluation criteria may, in one embodiment, correspond to particularevaluation measures. Evaluation criteria may include, in any suitablecombination and without limitation: (1) manual processes are clearlydefined and well documented for telephone, fax, and electronic manualorders; (2) internal ownership of manual orders is clearly delineatedand tracked throughout the process; (3) the process incorporates clear,documented, and available procedures to track performance, addresserrors, escalate problems, and resolve exceptions; (4) performancemeasures are defined, measured, and reviewed; (5) manual order intakelogs are complete, consistent, and kept updated; (6) CLECs 16 canreadily initiate a manual order; (7) CLECs 16 can access the status oforders; (8) capacity is available to scale for unexpected peaks indemand; (9) process status is tracked and reported to management; (10)the capacity management process includes adequate, complete, andconsistent procedures; (11) business and transaction volume (e.g.,orders submitted, calls received) measures are clearly defined and aretracked for capacity management purposes; (12) the business scenariosand conditions under which capacity adjustments would be made aredefined during capacity planning; (13) the capacity management processincorporates forecasting and trend analyses of business volumes andresource utilization; (14) contingency plans are documented and stepstaken to mitigate the impact of unexpected changes in capacity, businessvolumes, and resource utilization (including whether service qualityobjectives and workload fluctuations are considered in workforcescheduling); and (15) production and service quality objectives aredefined for capacity planning and management. Considerations relevant toone or more evaluation criteria may include whether the process isdocumented and followed, whether documentation is available to CLEC andILEC personnel, whether data is available and verifiable, whetheralgorithms for data analysis are defined and documented, and whetherreports are available.

Test Target Areas and Measures Process Area Sub-Process Area MeasuresCriteria Receive manual order Telephone and fax manual Accuracy andcompleteness of 5 order logging log Completeness and consistency ofprocess Electronic manual order Accuracy and completeness of 5 logginglog Completeness and consistency of process Process manual order Entryof manual order into Completeness and consistency 3 order processor ofprocess Send order response Delivery of error messages Completeness andconsistency and queries of process Delivery of confirmationsCompleteness and consistency and completions of process Status trackingand Status tracking and Completeness and consistency 1-2, 9 reportingreporting of process Problem escalation User-initiated escalationCompleteness and consistency 3 of process Capacity management Capacityplanning process Adequacy, completeness, and 10-15 consistency Processmanagement General management Completeness and consistency 6 practicesof operating management practices Performance measurementControllability, efficiency, and 3, 9 process reliability of processProcess improvement Completeness of process 3 improvement practices

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

G. POP Metrics Test

The test provides a comprehensive evaluation of ILEC systems andprocesses used to capture metrics associated with its retail andwholesale POP operations. In one embodiment, the focus is on thecapture, tracking, and reporting of POP metrics required by theregulatory entity. The test includes the following key components,without limitation: (1) metrics replication, using ILEC data and itsalgorithms to re-calculate metric values for a specified time period todetermine the accuracy of the ILEC calculations, (2) a data integrityevaluation that focusing on ILEC processes used to filter raw data foruse in calculating metric values, and (3) statistical analysis tocompare the metric values for the ILEC's wholesale operations with thevalues for the ILEC's retail operations or with suitable standards. Inone embodiment, this test may be conducted as a part of, or supplementedby, a comprehensive Performance Metrics Test that evaluates ILECsystems, processes, and other operational elements associated with itssupport for performance metrics, most preferably across multipledomains.

Metrics generation typically involves ILEC 14 gathering raw dataconcerning transactions, filtering the data as appropriate, storing thefiltered data in one or more databases, and generating reports based onthe stored data. In one embodiment, the ILEC 14 implements a system thatuses one or more emulation programs to monitor order processor 44. Theseprograms may submit pre-order and order transactions to order processor44 as if the transactions were from CLECs 16 (which might require thetransactions to pass through one or more OSS access system 20) or fromretail customers of ILEC 14 (which may require the transactions to flowthrough to order processor 44). The programs preferably submit thetransactions according to pre-defined scripts that attempt to replicatetypical patterns as to type and volume. The system monitors and recordsresponse times for the submitted transactions in one or more databases.ILEC 14 then uses this information to generate metrics for reporting tothe regulatory entity or otherwise. ILEC 14 may maintain data for allorders that are confirmed, completed, or rejected during the test periodand for all outstanding orders that were confirmed during the testperiod but were not completed or rejected at the end of the test period.

For example only and not by way of limitation, pre-ordering metrics mayinclude the elapsed time (e.g., in seconds) between submission of apre-order request and receipt of a response. Ordering metrics mightinclude the elapsed time (e.g., in hours) between receipt of a validorder request and the distribution of a confirmation or rejection, thepercentage of orders rejected, the percent of such confirmations sent ontime, the elapsed time between the notice to ILEC 14 of the ordercompletion date and distribution of the order completion notification,the percentage of notifications sent on time, the percentage of ordersthat flow-through, and any other appropriate metrics. Provisioningmetrics might include the interval (e.g., in days) between the receiptdate for an order and due date for completion of the order, the interval(e.g., in days) between the receipt date and the actual completion date(preferably excluding CLEC delays or other delays not the fault of ILEC14), the interval (e.g., in days) between the due date and the actualcompletion date, the percentage of commitments missed (preferablyexcluding those not the fault of ILEC 14), and any other suitablemetrics. These are just examples; the present invention contemplates anysuitable metrics according to the data available and particular needs.

Metrics Replication

To determine whether the ILEC 14 accurately calculates and properlyreports its POP metrics, the testing entity attempts to re-create thesemetrics using ILEC 14 filtered data, ILEC 14 algorithms, and ILEC 14descriptions of the metrics. For this purposes, ILEC 14 may develop itsown software that implements ILEC algorithms. Once the metrics have beengenerated, the testing entity can determine whether the calculatedresults match the results that ILEC 14 has reported.

Data Integrity

Since the metrics replication component uses filtered data, the testingentity may design and implement statistical samples to determine whetherthe filtered data used to calculate the metrics was correctly generatedfrom the raw data. Due to the complexity of the information systemsinvolved and the filtering processes used, it may not be possible toinvestigate all the systems and processes in the time available fortesting. As a result, it may be desirable for the testing entity todetermine whether a sufficiently reasonable level of confidence in theintegrity of the ILEC filtered data can be established.

In one embodiment, the data integrity investigation involves thefollowing steps, without limitation: (1) identify one or more fields inthe filtered data that are used most often in the metric calculations(this determination may be made separately for each of the pre-ordering,ordering, and provisioning metrics); (2) request that the ILEC 14identify where the earliest records of the data in these fields islocated and which ILEC personnel can best explain the records; (3)drawing on interviews with suitable ILEC personnel, determine which ofthese records to inspect; (4) identify a random sample of pre-order,order, and provisioning transactions and request ILEC 14 to providecopies of the associated records (each sample might be “stratified” toensure a representative cross-section); (5) treating the data in theserecords as the raw data with which the filtered data may be compared,compare the raw data with the filtered data for each sample; and (6)request ILEC 14 to research and explain any unexpected entriesencountered in the raw data.

The testing entity may trace the progress of transactions from pre-orderto order to provisioning over the duration of the test period. Forexample, the testing entity may request data for all order transactionssubmitted near the beginning of the test period and filtered data forall provisioned and still pending orders for the entire test period. Thetesting entity may compare the data for the submitted orders with thefiltered data for the provisioned and pending orders to ensure there nounexpected disappearances or appearances. As for sample-basedcomparisons described above, ILEC 14 may be given an opportunity toresearch and explain such discrepancies. If no significant unexplaineddiscrepancies are found, a reasonable level of confidence has beenattained.

Statistical Analysis

Using statistical techniques, the testing entity compares correctlycalculated ILEC wholesale metrics (which may be the metrics generated bythe testing entity rather than those generated by ILEC 14) with ILECretail metrics or other suitable standards. Since the testing entityprimarily relies on data collected during the test period, test periodconditions should be statistically similar to conditions outside of thetest period. Furthermore, although the testing entity may verify certainILEC-supplied data and probe data integrity in general, the testingentity may largely need to rely on the ILEC 14 to provide accurate testperiod data. Accordingly, the testing entity should have discussionswith ILEC 14 personnel to understand how data is collected and processedso as to determine whether the data will allow for correct overallinferences (barring some deliberate tampering with the data). Otherfactors that may cause differences between the test and retail data,such as geography (as reflected in the area code), number of lines inthe order, and type of order, should be accounted for to the extentpossible. For example, one geographic area may receive a higher level ofservice than another or might have a higher concentration of CLECs 16than another, such that ILEC 14 may be in parity within the area yet outof parity overall (or vice versa).

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how particularevaluation criteria may, in one embodiment, correspond to particularevaluation measures. Evaluation criteria may include, in any suitablecombination and without limitation:

Pre-ordering: (1) ILEC metrics are logically the same as those outlinedin applicable industry guidelines; (2) the ILEC's software andalgorithms are consistent with the metrics outlined in applicableindustry guidelines; and (3) ILEC reported metrics are correct;

Ordering: (4) ILEC metrics are logically the same as those outlined inany applicable industry guidelines; (5) the ILEC's software andalgorithms are consistent with the metrics outlined in applicableindustry guidelines; (6) the ILEC's reported metrics are correct; (7)selected filtered data used to generate metrics is consistent with thecorresponding raw data; (8) the metric values reported satisfyrequirements according to statistical analyses; and (9) metric valuesreported are consistent with data collected; and

Provisioning: (10) ILEC metrics are logically the same as those outlinedin any applicable industry guidelines; (11) ILEC software and algorithmsare consistent with the metrics outlined in applicable industryguidelines; (12) the ILEC's reported metrics are correct; (13) selectedfiltered data used to generate metrics is consistent with thecorresponding raw data; and (14) metric values reported satisfyrequirements according to statistical analyses.

Test Target Areas and Measures

Process Area Sub-Process Area Measure Criteria Validate the Identifycontrol points where Applicability and 1, 4, 10 information gatheringmeasurements are taken measurability of control points processesIdentify data sources for each Applicability and 1-2, 4-5, reportedmetric completeness of data sources 10-11 Identify tools ILEC 14 usesApplicability and reliability of 1, 4, 10 to collect data tools Validatemetric values Evaluate calculations Accuracy and applicability of 2-3,5-7, generated calculations 11-13 Evaluate tools used in the Accuracy,security, and 7, 13 calculations controllability of data housed in thetools Validate metric values Evaluate report format Consistency ofreported 9 reported results with data collected Evaluate report contentAccuracy of metrics reporting 8, 14 and completeness and applicabilityof measures

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

H. POP Documentation Test

This test evaluates the ILEC documentation developed to support CLECs 16with questions, problems, and issues relating to POP Domain activities.This test involves a high level review to determine whether ILECdocumentation in this area is prepared and distributed subject toacceptable management and business practices. Although the test does notattempt to comprehensively evaluate the accuracy of the contents of ILECdocumentation, a more detailed review may be warranted where documentsare essential to the establishment of electronic interfaces, performanceof transaction testing, or other critical activities. Portions of theILEC documentation relating to M&R, Billing, RMI, or other activitiesmay be reviewed in an analogous manner in connection with correspondingtests described below.

In one embodiment, operational analysis techniques are used for purposesof this test. Prior to initiation of the test, evaluation checklists arecreated to facilitate a structured review of ILEC documentation based onsuitable evaluation criteria. The review may include accessing one ormore websites through which documentation is made available to CLECs 16.The testing entity may evaluate certain documentation in the context offunctional tests described above to determine its utility in a morerealistic business environment. Inconsistencies, errors, unclearlanguage, and other content deficiencies that may impact the ability ofthe testing entity to successfully conduct the POP Domain testingdescribed above are noted and used as input to this document review.Interviews with pseudo-CLEC and ILEC personnel during such testing maycomplement these records. As for all the tests, exceptions may be raisedwhere issues are deemed to have a potentially significant impact on theability of CLECs 16 to conduct business operations.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how particularevaluation criteria may, in one embodiment, correspond to particularevaluation measures. Evaluation criteria may include, in any combinationand without limitation: (1) responsibilities and procedures fordeveloping, updating, and correcting documentation are clearly defined;(2) the responsibilities and procedures for maintaining distributionlists and distributing documentation are clearly defined, (3)distribution procedure allows the latest document version to be madeavailable to interested parties in electronic and paper versions in atimely manner, (4) training is provided for using documentation, (5)document version is indicated within each document and is clearthroughout the document, (6) documents provide cross-references and haveclear citations directing readers to relevant sources of additionalinformation, (7) documents instruct users how to notify ILEC 14 abouterrors or omissions, (8) documents correctly indicate scope and purpose,(9) documents contain table of contents, (10) documents are logicallyorganized with clear page numbering and section labeling; (11) documentscontain an adequate glossary of terms, including explanations ofrelevant acronyms; (12) documents contain methods and procedures tocorrectly execute processes; (13) documents identify the inputs andoutputs of processes; (14) documentation includes the expected resultsof process and cycle times; (15) the documentation adequately describesthe exception handling process; (16) documents provide useful contactlists and help desk numbers; (17) documents correctly describe the setupand access of relevant systems; (18) documents clearly define how tonavigate within systems (e.g., use of GUI screen prints); (19) documentscorrectly define all data fields; (20) the documents clearly andaccurately explain acceptable formats for data in data fields; (21)documents correctly distinguish between required and optional datafields; (22) documents define possible options after data entry (i.e.save, send, and cancel); (23) documents adequately describe expectedsystem responses and outputs; and (24) the documents provide adequatedescription of error messages and the possible steps for errorresolution.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria Acquire documentation Receive current Availability of up todate 14 documentation documentation Evaluate documentation Evaluatedocumentation Organization of  5-11 format documentation Evaluatedocumentation Clarity, accuracy, and 12-24 content completeness ofdocumentation Compliance to standards 20-21

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

I. POP Help Desk Test

This test provides a comprehensive operational analysis of ILEC helpdesk processes supporting CLECs 16 with questions, problems, and issuesrelating to POP Domain activities. For example, help desk 50 may supportCLECs 16 as to issues relating to creating and submitting pre-order andorder transactions, issues relating to orders that have already beensubmitted, and issues relating to EDI interface 30 or GUI interface 32(e.g., as to connectivity, access, and security). Help desk 50 may referCLECs 16 to other SMEs outside help desk 50 if appropriate. This testmay evaluate functionality, performance, escalation procedures,management oversight, security, or any other aspects of help desk 50. Inone embodiment, the test includes two parts: (1) a procedural review ofILEC procedures for performing and managing help desk functions; and (2)a subsequent analysis of help desk performance based upon interactionbetween pseudo-CLEC 18 and help desk 50 during POP Domain testingdescribed more fully above.

For the procedural evaluation, operational analysis techniques arepreferably used. The testing entity first generates evaluationchecklists to facilitate structured walk-throughs of help desk processesand interviews with help desk personnel and management to discuss theseprocesses. The testing entity also reviews the relevant ILECdocumentation and may solicit input from one or more CLECs 16 as to theILEC's help desk performance.

Observation targets for the walk-throughs may include, withoutlimitation: (1) help desk logs containing information relating to helpdesk inquiries received; (2) contact information for help desk 50 orappropriate management personnel; (3) an electronic “suggestion box”possibly associated with GUI interface 32 for receiving CLEC input; (4)read-only viewing of HTML pages or other files presented to the CLECs 16in association with GUI 38, for example, to verify that appropriateerror messages are conveyed to CLECs 16; (5) a training packet or othersuitable reference documentation that provides help desk personnel withdescriptions of all the error messages that may be generated and basicproblem solving techniques to be used in relation to each such errormessage.

CLEC participation may be solicited in several ways. In one embodiment,CLECs 16 receive surveys requesting feedback on particular interactionswith the help desk 50 concerning POP Domain issues. For example, thetesting entity may record the particular help desk 50 (of possiblymultiple help desks 50) that CLEC 16 contacted, the CLEC's descriptionof procedures ILEC 14 followed in responding to issues, and the CLEC'squalitative assessment of the level of support that ILEC 14 provided. Inaddition, CLECs 16 may be invited to participate in walk-throughs, toobserve CLEC interaction with help desk 50, to participate in relateddiscussions, or to have other suitable involvement.

The performance evaluation relies on a qualitative and quantitativeanalysis of selected data collected during POP Domain transactiontesting. In one embodiment, the testing entity establishes its own helpdesk within pseudo-CLEC 18 to interface with the ILEC's help desk 50.When issues arise during transaction testing, testers direct theirinquiries to the pseudo-CLEC help desk, which in turn places calls tothe ILEC help desk 50 to evaluate its performance in terms ofresponsiveness, timeliness of resolution, and accuracy of resolution.Such calls preferably encompass a variety of suitable test scenarios,but generally fall into two categories—calls that relate to specificerror messages received in response to submitted pre-orders and ordersand calls that relate to status checks or other questions unrelated tospecific errors.

Interactions with the help desk 50 are logged, typically including thedate the issue was referred to help desk 50, the particular transactionand issue, the outcome, the resolution date if any, and an error reasonassigned following resolution of the issue. If immediate resolution ofthe issue is not achieved, the issue status may be tracked untilresolution. Once a resolution is received at the pseudo-CLEC's helpdesk, it is communicated to a tester who may then, for example, makemodifications necessary to re-submit an associated transaction. Toevaluate the ILEC's help desk performance, information in the issue logsis analyzed and organized by transaction type, error reason, orotherwise. In addition, interviews with the pseudo-CLEC help deskpersonnel regarding their qualitative experience with the ILEC's helpdesk 50 may be conducted.

Test target areas and associated evaluation measures are summarized inthe table below. More specific evaluation measures may be used toevaluate test target areas that pertain to specific pre-ordering,ordering, and provisioning activities. The last column of the tableindicates how evaluation criteria may, in one embodiment, correspond toparticular evaluation measures. Evaluation criteria may include, in anycombination and without limitation: (1) all help desk responsibilitiesare defined; (2) scope of help desk services covers all key customerrequirements; (3) the scope and objectives of help desk 50 are clearlydefined, documented, and communicated to customers; (4) complete (i.e.beginning-to-end) description of the help desk process is documented;(5) the help desk process includes procedures for addressing errors andexceptions; (6) help desk 50 is responsive to CLEC telephone calls; (7)information provided by help desk 50 is accurate; (8) the help desk 50provides timely resolution of issues; (9) the help desk processincorporates complete and consistent call intake procedures (i.e.logging and acknowledgment); (10) help desk process defines criteria andprocedure for severity coding help desk calls; (11) help desk processincludes procedures for referral (both into and out of help desk); (12)the help desk process includes complete and consistent procedure forclosure logging; (13) the help desk process includes complete andconsistent procedure for issue status tracking and for reporting tomanagement; (14) help desk process includes complete and consistentprocedure for escalating user issues and problems; (15) help deskprocess includes complete and consistent procedures for capacityplanning; (16) the help desk process includes procedures for maintainingdata security and integrity; (17) any electronic help desk interfacesare easy to use; (18) the responsibilities for tracking help deskperformance are assigned; (19) help desk process performance measuresare defined and measured; (20) help desk process improvement proceduresare defined and the responsibilities are assigned.; and (21) the CLECs16 can readily interface with help desk 50.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria Respond to help desk Answer call Timeliness of call 2, 6 callCompleteness and consistency of process Interface with user Availabilityand usability of 2-3, 6, 19 user interface Log call Accuracy andcompleteness of 4, 8 call logging Record severity code Compliance ofcall logging severity coding Process help desk call Access to systems toAbility to access user records 1, 7, 16 observe user problems andtransactions Resolve user question Completeness and consistency 1-2,4-5, problem or issue of process 7-8, 10- Accuracy of response 11 Recordfollow-up is Accuracy and consistency of required process Follow-up oncommitments Measurability of adherence to response time Complete andaccurate follow- 19 up Close help desk call Log closure informationCompleteness, consistency, 11-12 and timeliness of process Accuracy oflogging Monitor status Track status Accuracy and completeness of 8-9,10, status tracking capability 13, 17 Consistency and frequency offollow-up activities Availability of jeopardy notification Report statusCompleteness and consistency 4, 10, 13 of reporting process Accuracy,timeliness, and accessibility of status report Request escalation Manageescalations Completeness and consistency 13-14 of procedure Manageworkforce Provide management Completeness and consistency 15 capacityoversight of process Review staffing plans Scalability of staff volume15 Provide security and Provide secured access Completeness and 16integrity applicability of security procedures, profiles, andrestrictions Controllability of intra- company access Manage the helpdesk Provide management Completeness and consistency 5, 12-13, processoversight of operating management 15-16, 18 practices Controllability,efficiency and reliability of process Completeness of processimprovement practices Capacity management Capacity management Adequacyand completeness 6-8, 15 process of process

Considerations relevant to particular evaluation criteria may include,without limitation (consideration for a criterion being listed after thenumber of the criterion): (1) the process is completely documented,ownership is defined for each process, and documentation is readilyavailable to CLEC and ILEC personnel; (2) key customer requirements aredefined, scope of help desk responsibilities is documented, and keycustomer requirements are met or exceeded by the documentedresponsibilities; (3) documentation available to CLECs 16 contains acomplete description of the process and contacts, documentation isreadily available to CLECs 16, and documentation and training arereadily available to the help desk personnel; (4) the process isformally documented, documented process is available to ILEC managementand staff, ILEC managers and staff are trained in documented process,and requisite contact numbers are available in the documentation; (5)process for handling an error or exception is defined and documented,error/exception processes are communicated to CLECs 16, process includescriteria for determining an error or exception, and ILEC help deskpersonnel are evaluated on their handling of errors and exceptions; (6)standards for timeliness exist, timeliness measures are aligned with thegenerally accepted industry standards, timeliness of the process ismeasured by help desk management, and help desk personnel are evaluatedon their response timeliness; (7) help desk personnel performing theprocess are trained, any documentation required to resolve issues isavailable to help desk personnel, the personnel are evaluated on theaccuracy of the information provided, and the personnel are evaluated onthe timeliness of the issue resolution; (8) suitable timelinessstandards are defined, the timeliness of the process is measured, andtimeliness measures are reported and managed; (9) a system for trackingcalls exists, the procedures for logging calls are defined anddocumented, procedures are taught in training, and personnel areevaluated on their performance and timeliness of call logging andtracking activities; (10) severity codes are defined, standards fordetermining severity codes are defined, specific actions are associatedwith specific severity codes, and personnel are evaluated on theirassignment and tracking of severity codes; (11) referral procedure isdocumented, documentation is available to proper ILEC and CLECpersonnel, processes for the timely updating of contact/referralinformation exist, and personnel are evaluated on the performance ofreferrals to and from help desk 50; (12) a system for tracking callsexists, system has functionality for closure posting, criteria whichmust be satisfied to close a call are established and documented,personnel are evaluated on the performance of closure posting, andprocess includes procedures for obtaining CLEC agreement of closure;(13) status of the process can be tracked, a system for tracking theprocess exists, responsibility for tracking the process and performanceof issue resolution is defined, performance reporting responsibilitiesare defined, and the responsible personnel are evaluated based on thetimeliness of issue resolution; (14) escalation procedures are definedand documented, process includes appropriate standards for escalation,and documentation of the procedures is available to ILEC and CLECpersonnel; (15) a capacity plan exists, data related to capacity iscollected, monitored, and reported, responsibility for data analysis isadequately defined and documented, algorithms for data analysis aredefined and documented, actions to change capacity are defined anddocumented, criteria for taking action are defined and documented, andresponsibility for taking action is assigned; (16) security controls aredocumented, penalties for not conforming to these security controls aredocumented, and security procedures and penalties are taught andenforced; (17) performance measures are documented and can be tracked, asystem for tracking performance exists, periodic measurements of processperformance are made, standards for performance are defined, actions tobe taken when standards are not met are defined and documented,responsibility for tracking performance is assigned, and performanceinfluences capacity management decisions; (18) CLEC and internal (ILEC)suggestions are solicited and collected, procedures for evaluatingsuggestions are defined and documented, the process for making changesis defined and documented, the responsibility for acknowledging,evaluating and responding to suggestions is assigned, and responsiblepersonnel are evaluated on timeliness of responses to and implementationof suggestions; and (21) process is documented, process is followed, anddocumentation is available to CLEC and ILEC personnel.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

J. POP Provisioning Parity Test

The test evaluates the ILEC systems, interfaces, and processes thatprovide provisioning for CLEC 16 orders to determine the degree to whichthis provisioning environment is in parity with provisioning for theILEC's retail orders. The focus of the evaluation is on activitiesoccurring downstream of order entry through service activation. Asdescribed above with respect to FIG. 12, the provisioning processtypically begins with the successful entry of an order into orderprocessor 44. CLEC orders may be entered in order processor 44 afterflowing through EDI interface 30 and/or GUI interface 32 in whole, inpart (order shell created in order processor 44 with manual entryrequired to complete the order), or not all (manual entry required forentire order at manual interface 34).

Once populated in order processor 44, the orders may flow toprovisioning systems 46, which may include an order control system thatcontrols the progress of orders through the provisioning process,distributes the orders to other provisioning systems 46 as appropriate,and returns status messages to order processor 44. From the ordercontrol system, the orders may flow through or be manually assigned to atranslation process, which attempts to load translations associated withthe orders in the appropriate ILEC CO switches. Where an error ariseswith respect to an order, one or more sub-systems and sub-processes maybe used to resolve the error so as to place the order in condition forhandling within the translation process. Within the translation process,one or more sub-systems and sub-processes may contribute to loading oftranslations to complete provisioning of the orders. Pre-order serviceinquiry, loop qualification, and other tasks may be needed for digitalsubscriber line (xDSL) orders. Although any evaluation measures andevaluation criteria particular to xDSL orders are not described below,additional evaluation measures and criteria analogous to those describedbelow may be used in connection with xDSL orders to the extent thatthose described below would be insufficient.

In one embodiment, operational analysis techniques may be used. Thetesting entity conducts structured walk-throughs of systems involved inthe provisioning process, interviews appropriate associated ILECpersonnel, and reviews associated ILEC documentation. In addition, ILECsample order files and other supplemental information may be reviewed.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures. For purposes of the evaluation measures, the followingsub-process definitions may be used: (1) internal order entry involvesthe flow of orders into order processor from EDI interface 30, GUIinterface 32, and/or manual interface 34 and, where necessary,administration of orders within an associated operations center; (2)workflow management includes administering the flow of orders in andbetween the components of the provisioning process; (3) workforcemanagement includes prioritizing order-related activities andapportioning activities to ILEC personnel; (4) assignment includesactivities in the provisioning process required to assign and/or reservenecessary facilities for the order; (5) service activation includescreating translations and loading them into or otherwise programming theILEC CO switches accordingly, testing the service, and “turning up” theservice for operation; and (6) service design includes defining thefacilities, activities, and other components needed for the service.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria Provisioning process Evaluate ILEC's internal Consistency andrepeatability 1-4, 12- parity order entry process as compared to retail13, 19-20 Evaluate workflow Consistency and repeatability 5-10, 14-management as compared to retail 15, 23-26 Evaluate workforceConsistency and repeatability 1, 3, 5, 7, management as compared toretail 9, 21-22 Evaluate assignment and Consistency and repeatability5-6, 15, translation process as compared to retail 24-25 Evaluateservice activation Consistency and repeatability 7-11, 16- process ascompared to retail 18, 25, 27 Evaluate service design Consistency andrepeatability 9-10, 17, process as compared to retail 26

In one embodiment, this test may evaluate three dimensions of parity inthe provisioning process: (1) parity in provisioning systems; (2) parityin provisioning procedures; and (3) parity in provisioning processexecution. As described above, comparison of the provisioning times forthe ILEC's wholesale and retail operations may be evaluated inconnection with the POP Metrics Evaluation Test. Evaluation criteria forthis test may include any one or more of the following, in any suitablecombination and without limitation:

Provisioning Systems: (1) work volumes within the order processor 44 areconsistently administered between retail and wholesale; (2) systems forprocessing and distributing orders from and within order processor 44are consistent between retail and wholesale; (3) the work volumes withinthe ILEC operations center are consistently administered between retailand wholesale; (4) systems for processing and distributing orders fromand within the ILEC operations center are consistent between retail andwholesale; (5) the work volumes within systems associated with theassignment and translation process are consistently administered betweenretail and wholesale; (6) systems for processing and distributing ordersin connection with the assignment and translation process are consistentbetween retail and wholesale; (7) the work volumes within the systemsused for service activation are consistently administered between retailand wholesale; (8) the systems for processing orders in connection withservice activation are consistent between retail and wholesale; (9) workvolumes within the systems used for handling special services areconsistently administered between retail and wholesale; (10) the systemsfor processing orders in connection with any special services areconsistent between retail and wholesale; and (11) systems used withinthe CO are consistent and comparable to retail. Suitable considerationsfor each of these criteria may include whether the systems are in factidentified with the task for which they are used, whether the system orassociated process is complete, whether correct usage of the system orassociated process is documented, and whether such correct usage isfollowed. Where different systems and/or associated processes are usedfor retail and wholesale, findings based on these criteria andconsiderations may be compared to determine parity.

Provisioning Procedures. (12) methods and procedures associated with theorder processor 44 are consistent, repeatable, and comparable betweenwholesale and retail; (13) methods and procedures exist to support theILEC operations center and interaction with internal ILEC systems, (14)methods and procedures associated with the ILEC order control center areconsistent, repeatable, and comparable between wholesale and retail;(15) methods and procedures associated with assignment and translationare consistent, repeatable, and comparable between wholesale and retail;(16) the methods and procedures associated with service activation areconsistent, repeatable, and comparable between wholesale and retail;(17) the methods and the procedures associated with handling specialservices are consistent, repeatable, and comparable between wholesaleand retail; and (18) methods and procedures used in the CO areconsistent, repeatable, and comparable between wholesale and retail. Foreach of these criteria, suitable considerations may include whether themethods and procedures are defined, complete, documented, and followed.Where differences are present between the retail and wholesale methodsand procedures, findings based on these criteria and considerations maybe compared to determine parity.

Provisioning Execution: (19) execution associated with order processor44 is consistent with that of the ILEC retail's order centers; (20)execution associated with the ILEC operations center is consistent withthat of its retail order centers; (21) the operations center is staffedwith similar abilities, advantages, and skill sets as the retail ordercenters; (22) the operations center has similar hours of operation asthe retail order centers; (23) execution associated with the ILEC ordercontrol system is consistent, comparable, and repeatable betweenwholesale and retail; (24) assignment and translation are executed in aconsistent, comparable, and repeatable manner between wholesale andretail; (25) translation loading is executed in a consistent,comparable, and repeatable manner between wholesale and retail; (26)processes for special services are executed in a consistent, comparable,and repeatable manner between wholesale and retail; and (27) theprocesses in the CO are executed in a consistent, comparable, andrepeatable manner between wholesale and retail. For certain criteria,such as criteria 19-20 and 23-27, suitable considerations may includewhether work volumes are managed, whether the process is complete,whether the process is different for different work volumes, and whetherthe process is followed. Although criteria 21-22 relate specifically tothe ILEC operations center associated with order processing, similarcriteria may apply to any appropriate ILEC center in which provisioningrelated processes may be performed. Where different processes are usedfor retail and wholesale, findings based on these criteria andconsiderations may be compared to determine parity.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

K. POP Provisioning Coordination Test

This test evaluates the ILEC's processes and operational environmentused to support coordinated provisioning with CLECs 16. The evaluationaddresses products and services that require coordinated provisioning tominimize customer disruption. The objectives are to evaluate thecompleteness and consistency of the provisioning coordination process,determine whether the process is well documented, and evaluate theaccuracy and completeness of measures for tracking performance.

In one embodiment, ILEC 14 supports a CLEC coordination center (CCC) toserve as the focal point for the coordinated provisioning process, whichbegins when the CCC receives order requiring provisioning coordination.Personnel associated with the CCC typically verify the order and contactCLEC 16 to confirm important order information such as the due date,order type, and number of lines involved. During actual provisioning,the CCC may direct the appropriate ILEC provisioning personnel (e.g.,technicians in the CO and switch translation personnel) through theprocess. Following provisioning, the CCC may contact CLEC 16 again toconfirm completion.

In one embodiment, the testing entity conducts operational analysesinvolving the following activities, without limitation: (1) targetedinterviews of ILEC personnel associated with its operations centerregarding the hand-off between the operations center and the CCC andregarding important activities such as UNE cutovers, LNP, orderprocessing, and the like; (2) targeted interviews of ILEC personnelassociated with the CCC regarding work assignment and coordinationprocedures with CLECs 16 and with other ILEC systems involved in theprovisioning process, regarding the CCC procedures to measure and trackcoordination procedures, and regarding the management oversight ofprocess improvements; (3) targeted interviews of the ILEC personnelassociated with its COs regarding work assignment and CCC coordinationprocedures involved with provisioning activities required, for example,at the main distribution frames (MDFs) of its CO, provisioningactivities required outside COs, translations required at the switches,or other important activities; (4) a review of the ILEC provisioningcoordination documentation; and (5) review of test scenarios and casestudies involving historical orders to evaluate performance andeffectiveness of the coordination process and the extent to whichapproved coordination procedures are practiced in the field.

This test may involve any appropriate test scenarios according toparticular needs. In a particular embodiment, the test uses scenarios29, 41, 49-51, 57, 59-60, 62, 70, 85, 91-94, 96-97, 102, 117, and127-132 listed in Appendix A. The test will preferably include one ormore scenarios involving the migration of circuits from ILEC 14 to CLECs16 and one or more scenarios involving the installation of new circuits.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures Process Areas Sub-Process AreasEvaluation Measures Criteria Support provisioning Identify ordersrequiring Availability, consistency, 9 coordination process coordinationwith CLECs repeatability, and comparability with retail Requestcoordination Consistency, repeatability, and 8 comparability with retailReceive notification of Consistency, repeatability, and 10-11provisioning schedule comparability with retail Timeliness ofnotification Manage coordinated Consistency, repeatability, and  1-7,13-14 provisioning cases comparability with retail Completeness andconsistency of operating management practice Controllability, efficiencyand reliability of process Completeness of process improvement practices

Evaluation criteria for this test may include any one or more of thefollowing, in any suitable combination and without limitation: (1) acomplete (i.e. beginning-to-end) description of the coordination processis defined; (2) coordination procedures are consistent; (3) theprocedures are documented, maintained, and published; (4) the proceduresare practiced in the field reliably; (5) the procedures are practiced inthe field efficiently; (6) process performance measures are defined,measured, tracked, maintained, and controlled; (7) process improvementpractices are complete; (8) the procedures to request coordination foran order are complete and consistent; (9) the procedures for identifyingorders requiring coordination are complete and consistent; (10) theprocedures for notification of the provisioning schedule are completeand consistent; (11) the notification is timely; (12) manualcoordination procedures with CLECs 16 and internal ILEC systems aredefined; (13) procedures for addressing errors and exceptions aredefined; and (14) escalation procedures are defined.

In one embodiment, system and processes used in the CO pertain tocutovers from ILEC switches to collocated or other CLEC switches. Suchcutovers may fall into three primary categories: (1) orders submitted bythe pseudo-CLEC 18 under the aegis of a participating CLEC 16, theseorders typically not involving live customers but possibly involvingLNP; (2) orders submitted by pseudo-CLEC 18 not under the aegis of aparticipating CLEC 16, these orders typically having ILEC simulated dialtone but not involving live customers or LNP; and (3) orders submittedby CLECs 16 involving live customers and possibly LNP. The primarypurposes of observing the cutover is to verify that ILEC 14 complieswith its internal policies and procedures, that ILEC 14 completes thework on the requested due date and time, and that ILEC 14 provisions theorder correctly. To accomplish these objectives typically requires thecoordinated efforts of several testing entity personnel at differentlocations, for example, at a NOC associated with CLEC 16 and at the ILECCO in which the cutover will occur. Similarly, ILEC personnel associatedwith the CCC and the CO will typically be involved.

In a particular embodiment, pseudo-CLEC personnel involved in thecutover may include a coordinator, an initiator, an implementationcontact, one or more MDF observers, and one or more CLEC observer and/orpseudo-CLEC NOC observer. A person may in certain cases fulfill two ormore of these duties. For example, the coordinator is typically one ofthe MDF observers. A checklist may be provided to each participantdetailing the responsibilities of the participant and any observationtargets, which may improve consistency from test to test. Particularresponsibilities may vary depending on the nature of the cutover. Forexample, a cutover involving an xDSL circuit might be conducted at leastpartially differently, and therefore tested at least partiallydifferently, than a cutover involving a DS3 circuit. The participantchecklists may be customized to each type of cutover (e.g., differentchecklists for xDSL and DS3 circuits) to improve the corresponding test.

Coordinator responsibilities may include, without limitation: (1)identify the ILEC cutover contact; (2) determine the total number ofcutover lines for the CLEC 16 associated with the cutover; (3) obtainbilling account numbers, company codes, carrier and customer nameabbreviations, customer terminal locations, facility data, and any othersuitable information from CLEC 16; (4) provide the collected CLECinformation to the initiator, who is responsible for creating theassociated orders; (5) collect, review, and understand ILECdocumentation describing ILEC policies and procedures for cutovers andLNP implementation, recording any deficiencies in the documentation; (6)generate an initial cutover schedule and provide it to the initiator,with a PON associated with each test instance; (7) provide the initialcutover schedule to CLEC 16 and request the CLEC 16 to install switchtranslations; (8) forward an updated schedule received from theinitiator to CLEC 16 and request subscription record staging; (9)interface with the implementation contact and assist in escalating lackof dial tone, improper staging, or other issues to CLEC 16; (10) notifythe ILEC cutover contact a specified time (e.g., two days) prior to thecutover execution for access to the ILEC CO; (11) coordinate the effortsof the remaining team members in during cutover execution (i.e. MDFobserver and CLEC NOC and/or pseudo-CLEC NOC observers); (12) followingcutover execution, generate a list of LNP telephone numbers, includingthe PON, the date ported, and other suitable information; and (13)create a provisioning verification report that documents pertinentobservations and anomalies associated with the coordinated cutover.

Iniator responsibilities may include, without limitation: (1) writingthe order corresponding to the cutover; (2) receiving the initialschedule from the coordinator; (3) informing the coordinator andimplementation contact of schedule changes and updating the scheduleaccordingly; and (4) submitting the order to the ILEC 14 and verifyingthe information on the confirmation from ILEC 14.

The implementation contact is the interface between the ILEC CCC, CLEC16, and the coordinator. The implementation contact responsibilities mayinclude, without limitation: (1) logging planned calls from the CCC foreach cutover order (e.g., two days prior, one hour prior, and followingexecution for closure) and calls from the CCC to report a lack of dialtone, unstaged subscription records, or other issues; and (2) referinformation received in CCC calls to the coordinator and the CLEC NOCobserver.

MDF observer responsibilities may include, without limitation: (1) underthe direction of the coordinator, observe ILEC personnel performing thecutover within the ILEC CO and note any pass/fail criteria fromappropriate test templates (e.g., five minute circuit monitoring,correct power level reading, head-to-head testing to verify the codingand framing, error detection, all circuits are tagged and identifiable,etc.); (2) notify the CLEC NOC observer that the MDF portion of thecutover is complete; and (3) following notification from the CLEC NOCobserver that the subscription record is active, verify one or more ILECtrigger translations.

CLEC NOC observer responsibilities may include, without limitation: (1)at some time (e.g., one day) before the cutover is executed, visit theCLEC NOC and review with CLEC personnel the procedures the CLEC NOCobserver will observe and perform; (2) in response to notification thatthe MDF portion of the cutover is complete, request the CLEC 16 toactivate the subscription record; and (3) initiate a test call andinform the MDF observers of the “call treatment” received (e.g., callthe donor switch to verify application of non-conditional trigger).

FIG. 13 illustrates an example process for performing such a coordinatedcutover in the context of the POP Provisioning Coordination Test.Activities that occur within the ILEC CCC are indicated in a firstcolumn 130, activities occurring within the CLEC NOC or pseudo-CLEC NOCare shown in a second column 132, and activities occurring within anILEC CO are shown in a third column 134. The illustrated process maysupplement or combine with the description above in any suitable manneraccording to particular needs.

Aspects of the POP Provisioning Parity and Provisioning CoordinationTests may be combined, if appropriate, into an overall POP ProvisioningProcess Test that evaluates: (1) parity of the complete set ofprocesses, procedures, systems, and tools used by ILEC 14 whenprovisioning services for CLECs 16; and (2) the processes, procedures,systems, and tools used in supporting coordinated provisioning with theCLECs 16. Organizations within ILEC 14 that contribute to theprovisioning process are tested. Such organizations may include orderprocessing, translations, facilities management, dispatch, inventory,problem resolution, engineering systems, and any other suitableorganizations. The objectives of this test may include: (1) determinethe completeness and consistency of ILEC provisioning processes andverify that the processes and systems used to provision retail andwholesale orders are in parity; (2) determine whether the provisioningprocesses are correctly documented, maintained, and published; (3)determine the accuracy, completeness, and functionality of ILECprocedures for measuring, tracking, projecting, and maintainingprovisioning process performance; (4) ensure that the provisioningcoordination processes have effective management oversight; and (5)ensure responsibilities for provisioning coordination processesperformance improvement are defined and assigned.

The testing methodology initially consists of interviewing ILEC SMEs inthe provisioning processes, reviewing ILEC documents that describeinternal processes and procedures, and verifying the ILEC's adherence toprocesses, procedures, and confirming parity. The interviews provideinsight into the contributions of various ILEC organizations. Requestsfor data are made to these organizations to supplement the interviews.Data may include documentation or sample output from systems or toolsused. Furthermore, discussions may be conducted with one or more CLECs16 to understand their experiences and issues with the provisioningprocesses. When appropriate, data may be collected from CLECs 16. Datamay include documented issues, documents and deliverables from ILEC 14,schedules, and internal CLEC documents. Information from the CLECs 16may be used as secondary sources in assisting the testing entity inpreparing interview questions. CLEC data may also be cross-referencedagainst suitable ILEC systems to confirm ILEC adherence to andconsistency with its stated processes and level of parity. Specific testscenarios may be created to test specific process operations. Collectedinformation is analyzed and assessed based on defined test objectivesand criteria. If necessary, further requests for interviews and/or dataare made to assist in the analysis. Once the analysis is complete, thetesting entity prepares a report summarizing its findings. The processareas, sub-process areas, evaluation measures, evaluation criteria, andconsiderations used in this test may include any appropriate combinationof those from the POP Provisioning Parity and Provisioning CoordinationTests described above, together with any other that may be appropriate.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

L. POP Scalability Test

This test evaluates certain architectural and operational aspects of theILEC's OSSs 12 relating to the access CLECs 16 are provided to the OSSs12 in connection with POP Domain activities. This test seeks todetermine the degree to which this CLEC access environment can be scaledto accommodate future order of magnitude increases in transactionvolumes and users. This may include a review of certain ILEC businessprocesses as to their ability to support scaling of the CLEC accessenvironment. Such business processes may include business forecasting,capacity planning, software development methodology, vendor selectionmethodology, or any other suitable business processes.

The environment to be reviewed encompasses ILEC OSS access system 20,including EDI interface 30, GUI interface 32, and manual interface 34for the POP Domain functions. The primary architectural components ofthese systems that are evaluated may include, without limitation: (1)network infrastructure; (2) hardware infrastructure; and (3) softwareinfrastructure, including one or more applications, tools, packages,middleware, databases, or other software components. Performance andutilization metrics may be reviewed to determine the present utilizationof each architectural component. Appropriate business and applicationgrowth projections may be reviewed to determine the expected growth ofeach architectural component. ILEC-preferred vendors may be evaluatedwith respect to continuous improvement, service level, industryleadership, market position, or other drivers that might affect theirability to provide scalable products to meet future capacityprojections.

The sources of data for this test may include walk-throughs, interviewswith associated ILEC personnel, review of associated ILEC documentation,and any other information sources. More particularly, activities mightinclude, without limitation: (1) identifying interface, process, andsystem objects for evaluation, identifying all documentation concerningthese evaluation objects that is available for review; (2) conductstructured interviews with appropriate key ILEC development and supportpersonnel using interview guides and questionnaires; (3) reviewdocumentation for evaluation objects and capacity planning processes,tools, and reports using one or more appropriate checklists; (4) inspectthe physical evaluation objects using one or more appropriatechecklists; (5) review findings in light of the results from stressvolume testing of EDI interface 30 to supplement conclusions; and (6)summarize finding and generate report.

Test target areas and their associated evaluation measures aresummarized in the table below. The last column of the table indicateshow evaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria POP scalability Evaluate mechanized Capacity of the interfaceto  1-5, 28, 30 interfaces support volumes. Scalability of the interfaceincluding, where applicable, qualities that may affect scalability suchas modularity, maintainability, supportability, recoverability, andfault tolerance Evaluate manual processes Capacity of the manual  6-16,19-22, processes to support volumes 28, 30, 36 Scalability of the manualprocesses, including, where applicable, qualities that may affectscalability such as flexibility, supportability, and reliabilityEvaluate systems Capacity of the systems to 20-28, 32-34 support volumesScalability of the systems Managing capacity Identify and evaluateAvailability and completeness 29-48 planning procedures of procedureApplicability and reliability of tools Review staffing plans Scalabilityof staff volume 29-48

Evaluation criteria for this test may include any one or more of thefollowing, in any suitable combination and without limitation:

Mechanized Interfaces: (1) EDI interface 30 is Y2K compliant; (2) an EDImigration path exists; (3) there are scalable connections between CLECs16 and the ILEC's servers; (4) the network is sized for current andprojected usage; and (5) the ILEC 14 supports appropriate networkprotocols for current and projected usage.

Manual processes: (6) ILEC 14 has the capability to handle fax and otherpaper source documents arriving from CLECs 16; (7) the number of papersource documents arriving from CLECs 16 per day is manageable withexisting or planned process and staff; (8) there are plans to eliminateor replace the function of receiving paper source documents from theCLECs 16; (9) there is an established process for confirming to CLECs 16the receipt of paper source documents; (10) there is an establishedprocess and sufficient number of people for collecting and distributingCLEC faxes; (11) there is an established process for addressingexception processing; (12) the number of persons entering data throughCLEC access system is adequate; (13) there is an established process forentering information from source documents via the appropriate ILEC OSS12; (14) there is an established process for getting access toprocedures associated with manual processes; (15) there is anestablished process for collecting and monitoring performance metrics;(16) performance is in fact monitored; (17) performance monitoringmetrics are accessible by ILEC staff; (18) there is an establishedprocess for forecasting of expected business growth; and (19) there isan established process for reviewing forecasts for accuracy.

Systems: (20) the operating systems in use will scale up to supportprojected growth; (21) the total amount of disk space per server issufficient; (22) there is an established capacity planning methodology;(23) there are redundant sites used for processing orders; (24) there isan established disaster planning methodology; (25) tape back-upfacilities are available; (26) there is an established process forcapacity planning and design; (27) there is an established methodologyfor maintaining and improving current service levels; and (28) there isan established methodology for monitoring the abilities of vendors toscale.

Capacity Planning: (29) there is an established process of obtainingdata to determine future growth patterns; (30) capacity planningprocedures exist; (31) there is an established process for developmentof the capacity planning procedures and their use in support ofscalability; (32) there is an established process for budgeting fundsand resources to support capital initiatives; (33) quality is ensuredduring the capacity planning process; (34) scalability is accounted forin capacity planning; (35) capacity planning process is based on the useof industry best practices; (36) there is an established approach toscalability; (37) system growth and capacity is monitored and needsanalysis is performed; (38) there is an established business-forecastingprocess to support capacity planning; (39) performance is monitored atacceptable levels; (40) performance monitoring software or utilities areused at each site; (41) databases are accounted for in the capacityplanning process; (42) databases are ISO 9000 and Y2K compliant; (43)operating system metrics are routinely collected; and (44) capacityplanning documentation is developed and available.

Staffing: (45) the number and timing of staff shifts for each workingday is consistent with the workload; (46) physical limitations forfuture staffing, such as office space, equipment, or personnel areidentified; (47) staff receives continuous training and/or crosstraining; and (48) there is an established approach to staffingmanagement during peak volume periods.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

Instead of or in addition to the POP Scalability Test, a separate POPCapacity Management Test may be conducted. This test provides a detailedreview of the safeguards and procedures in place to plan for, andmanage, projected growth in use of the EDI interface 30, GUI interface32, or any other shared systems for pre-order and order processing. Thetest will evaluate these functions for transaction volume tracking andforecasting, resource utilization tracking and forecasting, performancemanagement procedures, and capacity management. The objective of thetest is to determine the extent to which procedures to accommodateincreases in the pre-order and order transaction volumes and users arebeing actively managed.

Operational analysis techniques will be used to test the pre-order andorder capacity management processes. Structured interviews may beconducted with ILEC system administration personnel responsible for theoperation of EDI interface 30, GUI interface 32, or any other sharedsystems for pre-order and order processing. These interviews may besupplemented with analysis of ILEC capacity management procedures andevidence of related activities such as periodic capacity managementreviews; system reconfiguration and load balancing, and volume-increaseinduced upgrades. In one embodiment, test activities may include,without limitation: (1) review procedural and other documentationrelated to pre-order and order capacity management; (2) conductinterviews with key systems administration and support personnel asappropriate; (3) document findings; and (4) resolve exceptions.

Evaluation criteria for this test may include one or more of thefollowing, in any suitable combination and without limitation:

Data Collection and Reporting of Business Volumes, Resource Utilization,and Performance Monitoring: (1) there is an established process tocapture business and transaction volumes; (2) there is an establishedprocess for capturing resource utilization; (3) resource utilization ismonitored for appropriate system components and elements; (4) there isreasonable use of instrumentation and other tools to collect resourceutilization data; (5) performance is monitored at all applicable levels(e.g., network, database server, application server, client, etc.); and(6) there is reasonable use of instrumentation and other tools tomonitor performance.

Data Verification and Analysis of Business Volumes, ResourceUtilization, and Performance Monitoring: (7) there is an establishedprocess to forecast business volumes and transactions; (8) businessvolume tracking and forecasting data is at a suitable level of detail touse for capacity management; (9) there is an established process toreview performance of the business and transaction volume forecastingprocess; (10) there is an established process for verifying andvalidating performance data; and (11) performance monitoring results arecompared to appropriate service level agreements and other metrics

System and Capacity Planning: (12) capacity management process isdefined and documented; (13) resource utilization and capacity isconsidered in the planning process for capacity management; (14)performance monitoring results are considered in the planning processfor capacity management; and (15) the capacity management proceduresdefine performance metrics to trigger the addition of capacity, one ormore load rebalancing operations, or system tuning.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

M&R Domain

The general purpose of testing within the M&R Domain is to evaluate thesystems, processes, and other operational elements associated with theILEC's support of certain M&R activities affecting its wholesalecustomers—CLECs 16. The M&R Domain testing is designed to evaluate ILECfunctionality, evaluate its compliance with measurement agreements, andprovide a basis for comparison with the parallel M&R systems, processes,and operational elements supporting the ILEC's own retail operations.The report generated by the testing entity should preferably allow theregulatory entity to assess the net impact of M&R Domain issues that itidentifies on the ability of the CLECs 16 to operate in an opencompetitive environment for local telecommunications services in theparticular jurisdiction of interest.

In one embodiment, the M&R Domain may be broken down into a number ofprimary test target areas including, without limitation, key M&Rsystems, the M&R process, M&R performance measurement, M&R system andprocess documentation, M&R help desk support, network surveillancesupport, and the coordination of joint meetings with CLECs 16. Eachprimary test target areas may be broken down into increasingly discreteprocess and sub-process areas that identify particular areas to betested and the types of measures that apply to each area. According tothe present invention, tests have been developed to evaluate each testtarget area based on the scope of testing to be performed in each area.Particular exempla process and sub-process areas for each test targetarea, with exempla associated evaluation measures and evaluationcriteria, are described in more detail below.

There need not be a one-to-one correspondence between test target areasand specific tests. In one embodiment, the M&R Domain tests may includeone or more of the following, in any suitable combination and withoutlimitation: (1) a MRTAS Functionality Test, (2) a MRTAS PerformanceTest, (3) a MRTAS Scalability Test, (4) a Performance Measurement Test,(5) a Process Test, (6) a Documentation Test, (7) a Help Desk Test, (8)a Network Surveillance Support Test, and (9) a CLEC Joint MeetingCoordination Test. Example embodiments of these tests are described indetail below.

A. M&R MRTAS Functionality Test

As described above with reference to FIG. 1, OSS access system 20 serveas a gateway between CLECs 16 and ILEC OSSs 12, providing pre-processingoperations and an interface to “downstream” operations supported atthese OSSs 12. In one embodiment, referring to FIG. 14, the OSS accesssystem 20include a maintenance, repair, and trouble administrationsystem (MRTAS) 140 providing a MRTAS application 142 and a web-based orother suitable MRTAS interface 144. CLECs 16, and thus pseudo-CLEC 18,may use MRTAS interface 144 as a front end to interface with the ILEC's“core factory” M&R systems 146, which are particular OSSs 12. Ingeneral, MRTAS 140 is meant to replace manual processes for testingcircuits and for creating, monitoring, modifying, and closing anyoutstanding trouble tickets within the ILEC's M&R systems 146.

In one embodiment, MRTAS interface 142 includes a GUI that CLECs 16 mayuse to access MRTAS application 144 and, through MRTAS application 144,M&R systems 146. MRTAS interface 142 may support various screens (masks)for entering M&R transactions, which may include but are not limited toinitiating a circuit test, creating a trouble ticket, checking thestatus of a trouble ticket, modifying a trouble ticket, closing atrouble ticket, accessing a trouble history, or any other appropriateM&R transaction. While MRTAS interface 142 is described primarily asweb-based, communicating pages in HTML or XML over HTTP format forexample, MRTAS interface 142 may support any suitable communicationsformat according to particular needs. In general, MRTAS application 144receives the M&R transactions from MRTAS interface 142, routes thetransactions to the appropriate M&R systems 146 for processing, andreturns responses received from the M&R systems 146 to MRTAS interface142 for communication to the CLECs 16. MRTAS 140 may not actuallyperform any M&R functions itself.

Since multiple CLECs 16 may likely share MRTAS 140, several layers ofsecurity may be provided to limit unauthorized use and preserve dataconfidentiality. At the user level, the MRTAS 140 preferably limitsaccess to users with at least a valid user ID and password. Anadditional level of security may be used to validate each M&Rtransaction. As an example, a transaction to modify a trouble ticket mayrequire that the trouble ticket already have been created andcommunicated to M&R systems 146 for processing.

In general, this test evaluates whether: (1) the ILEC's MRTAS 140performs as documented in ILEC reference documentation; and (2) MRTASfunctionality is comparable to the functionality of systems used tosupport the ILEC's own retail customers. In one embodiment, this test isconducted in two corresponding phases, which may proceed in any suitablesequence or concurrently according to particular needs and capabilities.

In the first phase, existing MRTAS functionality is compared to theMRTAS functionality described in the ILEC's MRTAS referencedocumentation. To evaluate MRTAS 140, scenarios suitable for M&R testingare selected and MRTAS reference documentation is reviewed to determinehow MRTAS 140 should process each of these M&R scenarios. As part ofthis process, the testing entity may consider the completeness, clarity,and usability of the MRTAS reference documentation. For each screen(mask) available through MRTAS interface 142 and appropriate for one ormore selected scenarios, M&R transactions are submitted manually using aGUI and responses from the ILEC 14 are collected. Each of the functionsavailable via MRTAS interface 142 are preferably performed. During thedata entry process, any ILEC business rules for required or other fieldsmay be validated, for example, to ensure that fields actually need to becompleted and that invalid entries are flagged correctly. In oneembodiment, scenarios selected for this test may include one or more ofthe scenarios listed in Appendix A, in any suitable combination andwithout limitation. In a particular embodiment, these scenarios mayinclude scenarios 5, 7, 18-19, 30, 32, 37, 42, 86, 88-89, 91, 94, 99,106, and 108-113. However, any suitable scenarios may be used accordingto particular needs.

In a particular embodiment, on submitting a transaction, the tester isnotified via an acknowledgement that a server associated with MRTASinterface 142 has received the data. After the transaction has beenrouted by MRTAS 142 to the proper M&R system 146 and processed, aresponse is returned to the server and replaces the acknowledgement. Inthis case, timeliness of an acknowledgement depends of the timeliness ofMRTAS interface 142 only, while timeliness of a response depends on thecombined timeliness of MRTAS interface 142, MRTAS application 144, andthe M&R system 146 exercised by the transaction. The testing entityverifies that each MRTAS function behaves properly (i.e. as documented),noting any anomalies or discrepancies between the MRTAS documentationand its actual behavior.

Trouble tickets created as a result of submitted transactions arepreferably assigned a special “handle code” that MRTAS 140 interprets soas to prevent the dispatch of ILEC technicians without altering themanner in which the trouble tickets are processed within MRTAS 140. Thismay help to allow rigorous testing without disrupting the ILEC's regularbusiness operations. Underlying causes of any errors are preferablyanalyzed. For example, an error might result from unclear MRTASreference documentation, a tester error in entering data or incompleting the wrong screen (mask), or a functional deficiency of MRTAS140. Transactions involving user errors are preferably re-submitted. Atthe completion of the first phase of the test, the testing entitypreferably ensures that all trouble tickets entered into MRTAS 140 havebeen canceled.

In the second phase, the existing MRTAS functionality is compared to thefunctionality of other systems supporting M&R activities for the ILEC'sown retail customers. In one embodiment, the testing entity may conductstructured interviews of ILEC SMEs according to a previously preparedinterview guide or questionnaire. In addition to prepared questions,ILEC SMEs may be asked to “talk through” how the ILEC personnel wouldhandle particular scenarios. Information required for the ILEC personnelto process the scenarios may then be compared to the informationrequired when these same scenarios are processed using MRTAS 140.Additional relevant information (e.g., additional capabilities) shouldbe noted. The testing entity may also observe ILEC personnel performingtheir normal duties in supporting the ILEC's retail customers. Duringwalk through inspections, testing entity personnel should observe anytrouble report activities identified on a checklist provided, note thepresence and behavior of functions identified on the checklist, identifyanomalies relative to functions being observed, and note any functionsavailable for ILEC retail operations that are not available throughMRTAS 140. On-site visits and interviews may be supplemented with areview of relevant ILEC documentation or other suitable information.

Outputs from the test may include: (1) completed checklists from thefirst and second phase activities; (2) completed interview summaries;(3) summary reports of findings from each phase of the test, includingdiscussion of anomalies and relevant observations as to the usabilityand timeliness of MRTAS interface 142 and its retail counterparts; and(4) a summary report comparing the functionality of MRTAS 142 with itsretail counterparts, highlighting differences and contrasting ease ofuse in performing the functions tested.

Test target areas and their associated evaluation measures aresummarized in the table below. The last column of the table indicateshow evaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria Access to test capability Initiate circuit test Functionalityexists as documented 1 Timeliness 2 MRTAS usability 3 Document usability5 Conformance to industry standards 8 Trouble reporting Create/entertrouble report Functionality exists as documented 1 Timeliness 2 MRTASusability 3 Document usability 5 Conformance to industry standards 8 Addinformation to trouble Functionality exists as documented 1 reportTimeliness 2 MRTAS usability 3 Document usability 5 Conformance toindustry standards 8 Modify trouble report Functionality exists asdocumented 1 Timeliness 2 MRTAS usability 3 Document usability 5Conformance to industry standards 8 Retrieve trouble reportFunctionality exists as documented 1 status Timeliness 2 MRTAS usability3 Document usability 5 Conformance to industry standards 8 Cancel/closetrouble report Functionality exists as documented 1 Timeliness 2 MRTASusability 3 Document usability 5 Conformance to industry standards 8Trouble history Retrieve trouble history Functionality exists asdocumented 1 Timeliness 2 MRTAS usability 3 Document usability 5Conformance to industry standards 8 General Usability of MRTAS and MRTASusability 4-4 associated documentation Document usability 5-6 Functionalequivalence Functional equivalence M & R functionality, process, 7 andresponsiveness for ILEC retail systems not materially different fromMRTAS

Evaluation criteria for this test may include, in any suitablecombination and without limitation: (1) whether the user is able tosubmit the transaction or perform the operation using MRTAS 140 andreceive a satisfactory response; (2) whether the user receives timelyacknowledgements and responses; (3) whether MRTAS 140 is user-friendlywith respect to the transaction or operation; (4) whether MRTAS 140 isuser-friendly system for interacting with M&R systems 146 generally; (5)the ILEC reference documentation is adequate in relation to thetransaction or operation; (6) ILEC reference documentation is adequatein relation to interactions with the M&R systems 146 generally; (7)MRTAS 140 provides functionality, process, and response times equivalent(at least not materially different from) M&R systems available tosupport the ILEC's retail customers; and (8) MRTAS 140 providesfunctionality in conformance to industry standards.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

B. M&R MRTAS Performance Test

This test evaluates the responsiveness of MRTAS 140 to CLECs 16 undernormal and stress conditions. Performance may be measured with respectto any suitable historical, current, or projected transaction volumes.In one embodiment, if MRTAS 140 shares hardware, software, and otherresources with ILEC provisioning systems, the execution of this test maybe coordinated with appropriate POP Domain performance testing describedabove. Because this test is not designed to evaluate MRTAS functionality(see the M&R MRTAS Functionality Test described above) or the ILEC's M&Rprocess (see the M&R Process Test described below), preferably onlyvalid transactions are submitted and a special handle code (describedabove) is used to prevent dispatch of ILEC technicians.

Due to the high transaction rate required for MRTAS performance testing,interaction with MRTAS interface 142 is preferably automated using ascripting tool. For example, a scripting tool might include softwarethat polls an instruction table for transactions to be submitted,collects appropriate information for these transactions from a datatable, and sends transactions to MRTAS interface 142 in the appropriatesequence at a pre-defined rate. Transactions may be generated. andsubmitted using transaction engine 36 described above or a similarsystem designed specifically for M&R transactions as opposed to POPtransactions.

In one embodiment, from a tester perspective, trouble administrationusing MRTAS 140 is a two step process. Referring to FIG. 15, in a firststep, M&R transactions are submitted to M&R systems 146 using anappropriate GUI (through MRTAS interface 142 and MRTAS application 144)and responses are returned to a server associated with MRTAS interface142. This is illustrated using arrows T1 through T7. Subsequently, aseparate query is used to retrieve responses from the server,illustrated using arrow T9. The time “T1T8” is a function of thecombined responsiveness of the MRTAS interface 142, the MRTASapplication 144, and the M&R systems 146 and the connectivity betweenthem. Because the purpose of this test is to test MRTAS performanceonly, a suitable time interval for this test may be defined as time“T2T7”—the interval from receipt of an instruction by MRTAS application144 to exit of a response from MRTAS application 144. Use of thisinterval to measure MRTAS performance might not be appropriate unlessthe links providing connectivity between MRTAS application 144 and theM&R systems 146 have sufficient capacity to prevent bottlenecks or anyother sources of delay during testing. In the preferred case, times“T3T4” and. “T5T6” are substantially constant and substantiallyindependent of transaction volume. In addition, the responsiveness ofM&R systems 146 (time “T4T5”) should be substantially unaffected bychanges in wholesale volumes, which typically account for only a smallpercentage of the total M&R volumes. In one embodiment, time “T0T9” isnot evaluated, since it depends on the connectivity between the CLECfront-end GUI and the server associated with MRTAS interface 142, whichmay be vary among CLECs 16. For example, some CLECs 16 might have 56kbps access to the server while others might have much faster T1 access.In addition, CLECs 16 might have the option to bypass MRTAS interface142 in favor of other mechanisms for submitting transactions. However,time “T0T9” may be evaluated where appropriate.

Specific activities for this test may include, without limitation: (1)create test cases based on M&R scenarios, each of which may supporttesting of a number of MRTAS functions, preferably so that all scenariosare represented and all functions are covered; (2) after the test caseshave been created, develop and document a test approach and expectedresults for each test case using MRTAS documentation (the actual testresults may be subsequently compared with this document); (3) use thesedocuments to provide the data to execute the test (where the exact datarequired to perform certain functions cannot be predetermined, due tothe logic embedded in the MRTAS 140 or otherwise, ILEC MRTASdocumentation may also be used during test execution and any errors ordiscrepancies in the documentation noted as input to the M&RDocumentation Test); (4) feed transaction sets to MRTAS 140 using thetransaction engine 36 or otherwise; (5) periodically exercise MRTASfunctionality manually during test execution, in addition to use of thetransaction engine 36, and evaluate accessibility of MRTAS interface 142where appropriate; (6) observe and record all performance, operability,and other information relevant to the evaluation criteria for the test,preferably automatically capturing certain performance data using MRTAS140 and transaction engine 36; (7) ILEC 14 preferably monitors MRTASinterface 142 to identify any bottleneck conditions; (8) ensure allgenerated trouble tickets are canceled/closed; (9) request the ILEC 14to reset the test bed for the next test (if appropriate) or clean upILEC production databases; (10) analyze execution, observation, andperformance reports; and (11) document the findings and generate summaryreport. Activities (1) through (3) may be considered to be entrancecriteria for the test, along with all global entrance criteria havingbeen satisfied. Exit criteria may be limited to global exit criteria.

Similar to the POP EDI Interface Functional Test described above, MRTASresponsiveness is preferably tested under three conditions: (1) presentday loads, (2) projected future loads, and (3) stress loads. In anexample embodiment, each day consists of eleven base hours and one peakhour, transaction volume for a peak hour being 150% of transactionvolume for a base hour. In a pure test environment, the stress testmight evaluate MRTAS performance under exponentially or otherwiseincreasing transaction volumes until the point of failure. However,where MRTAS testing is conducted in a production environment, it may bedesirable to simply scale the peak volumes by 150% for the stress test.Any appropriate relationship between the base, peak, and stress volumesmay be established. The present invention also contemplates testing onlya single volume (e.g., peak) rather than multiple volumes (e.g., peakand stress) that are higher than normal. In a particular embodiment, thetest involves approximately four hours of normal volume testing, anapproximately thirty minute ramp up to the peak volumes, approximatelyone hour of peak volume flow, and an approximately thirty minute rampdown to the normal volumes. The process may be repeated as often asdesired, for example, executing this pattern on two successive days.

As just one example, a present transaction volume for purposes of thistest may be computed as follows: (1) determine the total number ofcircuits leased from ILEC 14; (2) based on the historical rate oftrouble reports as a percentage of leased circuits, determine the numberof trouble reports generated per month; (3) using the assumption that acertain percentage of all these trouble reports occur on weekdays,determine the average number of daily trouble reports per weekday; (4)assuming each day consists of eleven base hours and one peak hour at150% of the base hour volume, determine the base hour and peak hourtrouble report rates; (5) determine a suitable distribution oftransactions among the various M&R transaction types using historicaldata or in another suitable manner; (6) determine the rates for eachtype of transaction; (7) if the test will be executed in the ILEC'sproduction environment, reduce the rates by the estimated rates of livetransactions that will also be processed during the test; (8) where therates for certain types of transactions are less than one per hour,adjust the rates such that at least one transaction of each transactiontype will be submitted each hour; and (9) where the rate for anyspecialized transaction must match the rate for some other transaction,adjust the rates accordingly. Where there are multiple types of lesseesof leased ILEC circuits, these or other suitable calculations may beseparately applied to each type of circuit. The projected future loadsand stress loads may be determined analogously, using suitable forecastsand scaling factors, respectively. It may be desirable to conduct stresstesting at a time when the number of live transactions is relativelyminimal, such as in the evening or on a weekend (the estimated number oflive transactions being adjusted downward accordingly).

Test target areas and their associated evaluation measures aresummarized in the table below. The last column of the table indicateshow evaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria Access to test capability Conduct circuit test Performancedegradation 1-8 Trouble reporting Create trouble ticket Performancedegradation 1-8 Status trouble ticket Performance degradation 1-8 Modifytrouble ticket Performance degradation 1-8 Cancel/close trouble ticketPerformance degradation 1-8 Trouble history access Access troublehistory Performance degradation 1-8

Evaluation criteria for this test may include, in any suitablecombination and without limitation: (1) correctness of the response atnormal volumes; (2) correctness of the response at peak volumes; (3)correctness of response at stress volumes; (4) timeliness of theresponse at normal volumes as compared to ILEC specifications or otherstandards; (5) timeliness of the response at peak volumes volumes ascompared to ILEC specifications or other standards; (6) timeliness ofresponse at stress volumes; (7) timeliness of response at stress volumesas compared to ILEC specifications or other standards; and (8) MRTASperformance does not degrade significantly at peak volumes versusperformance at normal volumes. Results may be expressed as raw data ormay be expressed using any appropriate statistical techniques (e.g.,median, mean, standard deviation, variance, etc.).

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

C. M&R MRTAS Scalability Test

This test evaluates the technical and operational environment associatedwith the ability of CLECs 16 to access ILEC OSSs 12 in connection withM&R activities. The test is designed to determine the degree to whichthis technical and operational environment can be scaled up toaccommodate order of magnitude increases in the transaction volumes andusers. The test focuses on MRTAS 140, including MRTAS interface 142 andMRTAS application 144. Aspects of ILEC M&R process are also evaluated interms of their ability to support such scaling (the overall M&R processmay be evaluated in the M&R Process Test, as described below). No actualsystem testing is conducted as part of this evaluation—conclusions aboutthe ILEC's ability to scale its M&R environment is based on inspections,interviews with ILEC subject matter experts, review of pertinent ILECdocumentation, and the like. This test may be performed as part of amore comprehensive scalability evaluation of OSS access system 20.Moreover, instead or in addition to this test, a separate M&R CapacityManagement Test may be performed, analogous to the POP CapacityManagement Test described above.

In general, this test is designed to provides a detailed review of avariety of MRTAS features relating to scalability, including but notlimited to: (1) its overall modularity; (2) the architectures anddesigns of its associated network, databases, hardware, software, andother resources; (3) associated development methodologies and practices;(4) performance monitoring and management capabilities; and (4) theassociated personnel. Entrance criteria may include that all globalentrance criteria have been satisfied, an appropriate test-specificinterview guide or questionnaire has been developed, interviewees havebeen identified and scheduled, and a detailed evaluation checklist hasbeen completed. Test activities are preferably conducted by experiencedInformation Technology (IT) professionals and may include: (1) collectappropriate information; (2) perform walkthrough inspection of ILECfacilities that may be relevant to scalability; (3) perform structuredinterviews and documentation reviews; (4) evaluate current performanceand utilization metrics for each technical component within theenvironment to determine its present level of utilization; (5) determinethe extent to which each technical component can scale based on industryexperience, appropriate benchmarks, vendor declarations, and any otherinformation; (6) evaluate any business and other suitable growthprojections to determine what growth may be expected for each technicalcomponent; (7) evaluate the pertinent business processes to determinetheir ability to support the scaling of the technical components; (8)complete the evaluation checklist and interview summaries; and (9)develop and document findings in report. Exit criteria may be limited toglobal exit criteria.

Test target areas and their associated evaluation measures aresummarized in the table below. The last column of the table indicateshow evaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Areas Sub Process Areas MeasuresCriteria MRTAS Scalability 1-10 Scalability In addition to scalability,the components are evaluated, where applicable, for these qualities thatcan affect scalability: Modularity Maintainability SupportabilityRecoverability Fault tolerance

Evaluation criteria for this test may include any one or more of thefollowing, in any suitable combination and without limitation: (1)scalability is a key driver in determining capacity planning; (2)scalability is performed at all stages during life of an initiative; (3)volumes being processed are monitored regularly; (4) processes forbusiness forecasting are in place and are used to determine long rangecapacity; (5) ISO-9000 compliance is certified; (6) the software isdesigned and developed using a formal methodology; (7) softwarearchitecture is flexible, including loosely coupled but cohesivecomponents that scale independently of one another; (8) the routing ofrequests is data-driven (e.g., table- or file-driven) as opposed tomanual; (9) ILEC 14 has defined software maintenance process accordingto which software is monitored regularly; and (10) interfaces to CLECs16 conform to industry standards.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

D. M&R Metrics Test

The test provides a comprehensive evaluation of ILEC systems andprocesses used to capture metrics associated with its retail andwholesale M&R operations. In one embodiment, the focus is on thecapture, tracking, and reporting of M&R metrics required by theregulatory entity. The test provides a structured review of the M&R dataprocessing, metrics calculation, and metrics reporting systems andprocesses, which may focus on: (1) metrics replication, using ILEC dataand algorithms to re-calculate metric values for a specified time periodto determine the accuracy of the ILEC calculations, (2) a data integrityevaluation that focusing on ILEC processes used to filter raw data foruse in calculating metric values, and (3) statistical analysis tocompare metric values for the ILEC's wholesale operations with thevalues for the ILEC's retail operations or with suitable standards. Inone embodiment, this test may be conducted as a part of, or supplementedby, a more comprehensive Performance Metrics Test that evaluates ILECsystems, processes, and other operational elements associated with itssupport for performance metrics, most preferably across multipledomains.

Metrics generation typically involves ILEC 14 gathering raw dataconcerning transactions, filtering the data as appropriate, storing thefiltered data in one or more databases, and generating reports based onthe stored data. In one embodiment, this test may include: (1)surveillance of the ILEC's trouble report processing activitiesassociated with its M&R systems 146; (2) review of ILEC M&Rdocumentation; (3) structured interviews with ILEC SMEs; (4)re-calculating ILEC M&R metrics for a specified time period, using theILEC's data and algorithms to attempt to replicate the ILEC's metricvalues; (5) verifying that filtered data used to calculate ILEC metricswas correctly generated from the raw data; and (6) statisticallycomparing the metrics generated during testing to standards or theILEC's retail metrics, depending on the metric. The testing entity mayalso observe CLEC activities and interview CLEC personnel to furthervalidate one or more of these test components.

Surveillance

Surveillance of the ILEC's trouble report processing activities,reviewing its documentation, and interviewing its SMEs may all beperformed in an effort to accurately capture the M&R process flows, inthe form of diagrams, descriptions, or otherwise. These M&R process“maps” are then preferably submitted to ILEC 14 to confirm theiraccuracy. Following confirmation of their accuracy, the maps may be usedto identify differences between ILEC M&R systems and processes forretail and wholesale operations, as described more fully below inconnection with the M&R Process Parity Test. Differences identifiedprior to the completion of the structured interview component may beincorporated into interviews, for example, to allows ILEC 14 to explainthe reasons for such differences.

Metrics Replication

To determine whether the ILEC 14 accurately calculates and properlyreports its M&R metrics, the testing entity attempts to re-create thesemetrics using ILEC 14 filtered data, ILEC 14 algorithms, and ILEC 14descriptions of the metrics. For this purposes, ILEC 14 may develop itsown software that implements ILEC algorithms. Once the metrics have beengenerated, the testing entity can determine whether the calculatedresults match the results that ILEC 14 has reported.

Data Integrity

Since the metrics replication component uses filtered data, the testingentity may design and implement statistical samples to determine whetherthe filtered data used to calculate the metrics was correctly generatedfrom the raw data. Due to the complexity of the information systemsinvolved and the filtering processes used, it may not be possible toinvestigate all the systems and processes in the time available fortesting. As a result, it may be desirable for the testing entity todetermine whether a sufficiently reasonable level of confidence in theintegrity of the ILEC filtered data can be established.

In one embodiment, the data integrity investigation involves thefollowing steps, without limitation: (1) identify one or more fields inthe filtered data that are used most often in the metric calculations(this determination may be made separately for each M&R function); (2)request that ILEC 14 identify where the earliest records of the data inthese fields is located and which ILEC personnel can best explain therecords; (3) drawing on interviews with suitable ILEC personnel,determine which of these records to inspect; (4) identify a randomsample of transactions and request ILEC 14 to provide copies of theassociated records (each sample may be “stratified” to ensure arepresentative cross-section); (5) treating the data in these records asthe raw data with which the filtered data may be compared, compare thisraw data with the filtered data for each sample; and (6) request theILEC 14 to research and explain any unexpected entries encountered inthe raw data.

The testing entity may trace the progress of transactions over theduration of the test period. For example, the testing entity may requestdata for all transactions submitted near the beginning of the testperiod and filtered data for all still pending requests for the entiretest period. The testing entity may compare the data for the submittedtransactions with the filtered data for the closed and pending requeststo ensure there no unexpected disappearances or appearances. As for thesample-based comparisons described above, ILEC 14 may be given anopportunity to research and explain such discrepancies. If nosignificant unexplained discrepancies are found, a reasonable level ofconfidence has been attained.

Statistical Analysis

Using statistical techniques, the testing entity compares correctlycalculated ILEC wholesale metrics (which may be the metrics generated bythe testing entity rather than those generated by ILEC 14) with ILECretail metrics or other suitable standards. Since the testing entityprimarily relies on data collected during the test period, test periodconditions should be statistically similar to conditions outside of thetest period. Furthermore, although the testing entity may verify certainILEC-supplied data and probe data integrity in general, the testingentity may largely need to rely on the ILEC 14 to provide accurate testperiod data. Accordingly, the testing entity should have discussionswith ILEC 14 personnel to understand how data is collected and processedso as to determine whether the data will allow for correct overallinferences (barring some deliberate tampering with the data). Otherfactors that may cause differences between the test and retail data,such as geography or complexity of issues, should be accounted for tothe extent possible. For example, one geographic area may receive ahigher level of service than another or might have a higherconcentration of CLECs 16 than another, such that the ILEC 14 may be inparity within the area yet out of parity overall (or vice versa).

Test target areas and their associated evaluation measures aresummarized in the table below. The last column of the table indicateshow evaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria Retail metrics Network trouble report rate Accuracy 1measurements and process Percentage of subsequent Accuracy 1 reportsmeasurements and process Missed appointments Accuracy 1 measurements andprocess Repair interval Accuracy 1 measurements and process Wholesalemetrics Network trouble report rate Accuracy 1 measurements and processPercentage of subsequent Accuracy 1 reports measurements and processMissed appointments Accuracy 1 measurements and process Repair intervalAccuracy 1 measurements and process

Evaluation criteria for this test include whether the metric at issue isreported accurately using proper metric calculation algorithms and datafor which integrity has been properly maintained.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

E. M&R Process Test

This test evaluates the equivalence of the ILEC's end-to-end M&Rprocesses for its retail and wholesale operations. In one embodiment,the test includes several parts, including but not limited to: (1) usingM&R process flow “maps” to determine whether substantive differencesexist between the ILEC's retail and wholesale M&R processes; (2)observing the ILEC trouble handling process from the perspective of oneor more CLECs 16; and (3) executing selected test scenarios to analyzeILEC trouble handling performance for these scenarios.

For part one of the test, ILEC M&R process flows are mapped as describedabove in connection with the M&R Performance Metrics Test. As examples,the testing entity may create maps for M&R processes such as reactivemaintenance for retail and wholesale single line POTS service. ILECpersonnel may be interviewed using an appropriate interview guide orquestionnaire in developing suitable process maps, as described above.The testing entity compares the process flows for ILEC retail andwholesale M&R operations to identify any differences and determine thebusiness implications of such differences.

For part two of the test, the ILEC's trouble handling process isobserved from the perspectives of one or more CLECs 16. As an example,testing entity personnel may spend a period of time, weeks for example,within CLEC network operations centers to monitor the end-to-end troublehandling process from the perspective of CLECs 16 for trouble ticketscreated during the time period. The testing entity is thereby able toidentify issues and problems CLECs 16 encounter with respect to theILEC's trouble handling process. Appropriate CLEC personnel associatedwith these network operation centers may be interviewed to discuss suchissues and problems. ILEC reports for trouble tickets that the observedCLECs 16 create during the test period may also be analyzed in relationto observations made at CLEC NOCs.

For part three, selected test scenarios are executed using the ILEC'stest bed circuits to obtain a sample of ILEC M&R service performancemeasures for certain types of trouble repair scenarios. In oneembodiment, test scenarios appropriate for this test may includescenarios 86-89, 94, 99, 106, 108, 110, and 113-114 listed in AppendixA. However, the present invention contemplates any suitable scenariosbeing used. The testing entity provisions the test bed circuits toexecute the selected scenarios and has ILEC 14 insert faults,corresponding to the requirements of the particular scenarios, into thetest bed circuits. After insertion of the faults, the testing entitycreates trouble tickets using the MRTAS 140 to cause ILEC technicians tobe dispatched to repair the faults.

Resolutions of the inserted faults are tracked through the ILEC M&Rprocess. All contacts with the ILEC 14, activities of its personnel, andsignificant events are preferably observed and recorded (e.g., testrequest time, dispatch decision, dispatch rationale, dispatch time,trouble report submission time, time the trouble was cleared, timenotice of completion was received, CLEC notifications, etc.). Uponreceiving notification of a completed repair from ILEC 14, the testingentity will preferably physically, visually, or otherwise verify thatthe inserted fault was actually repaired. The testing entity analyze theILEC trouble handling performance for the particular M&R scenariostested, which preferably allow certain inferences to be made as to ILECperformance generally. Interested CLECs 16 may be invited to participatein the fault insertion, repair, and reporting process, the testingentity managing CLEC involvement to ensure that ex parte CLEC-ILECcontact (i.e. direct contact between CLEC 16 and ILEC 14 not involvingthe testing entity) is avoided.

Test target areas and their associated evaluation measures aresummarized in the table below. The last column of the table indicateshow evaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria End to end Process flows Comparison of 1 process - resalewholesale with retail End to end Process flows Comparison of 2 process -UNE-P wholesale with retail End to end Process flows Comparison of 3process - UNE-L wholesale with retail End to end M & R scenarioTimeliness and 4 process - Resale testing accuracy End to end M & Rscenario Timeliness and 4 process - UNE-P testing accuracy End to end M& R scenario Timeliness and 4 process - UNE-L testing accuracy

Evaluation criteria for this test may include one or more of thefollowing, in any suitable combination and without limitation: (1)parity between the ILEC retail and resale M&R processes; (2) paritybetween ILEC retail M&R processes and ILEC M& R processes for UNE-P; (3)parity between ILEC retail M&R processes and ILEC M&R processes forUNE-L; and (4) ILEC 14 repairs a fault in a test bed circuit for aspecified scenario within a specified time after ILEC 14 receives thetrouble ticket from the testing entity via MRTAS 140, the time to clearpossibly depending on the particular scenario. Considerations relevantto the first three evaluation criteria may include, without limitation:(1) ILEC 14 meets commitment times to CLECs 16; (2) on repaircompletion, ILEC 14 reports correct disposition code to CLEC 16; (3)upon initiation by CLEC 16 of a designed trouble report, ILEC 14provides a trouble ticket number; (4) upon initiation by CLEC 16 of atrouble report, ILEC 14 provides an estimated time to repair; (5) theILEC 14 provides CLECs 16 large business user trouble report priorityhandling as may be done with the ILEC's large business user troublereports; (6) the ILEC 14 provides status information on a trouble ticketupon request from CLEC 16; (7) the ILEC 14 provides escalation of atrouble report upon request from CLEC 16; (8) ILEC 14 notifies CLECs 16upon resolution of trouble reports; (9) ILEC 14 notifies CLECs 16 ofmissed repair appointments at parity with the ILEC's retail customers,using the same time frames it uses for its own end users, itself, orother entities; (10) ILEC 14 will initiate a dispatch upon request fromCLEC 16; (11) ILEC 14 will contact CLECs 16 to authorize premise visits;(12) ILEC 14 will quote to CLEC 16 time and charges applicable at thecompletion of a premise visit; (13) ILEC 14 will notify CLECs 16 if asubsequent premise visit is necessary; (14) ILEC 14 will verify andrepair CO features and functions on trouble reports communicated to ILEC14 by telephone; and (15) the ILEC 14 will transfer a call or providethe telephone number for the duty supervisor in the repair center ifrequested by CLEC 16.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

F. M&R Documentation Test

This test evaluates ILEC documentation that CLECs 16 use to interactwith ILEC 14 with respect to their M&R activities. The test is designedto evaluate the structure and content of the M&R documentation and M&Rsections of other ILEC documentation in terms of clarity, accuracy, andcompleteness. The test may also evaluate document management processesassociated with such documentation, for example, production,distribution, revision, and quality control processes for M&R relateddocumentation. The evaluation of whether M&R functionality matches thefunctionality described in the ILEC documentation is preferablyevaluated as part of the M&R MRTAS Functionality Test described above.

Entrance criteria for the test may include all global entrance criteriahaving been satisfied, an appropriate test-specific interview guide orquestionnaire having been developed, interviewees having been identifiedand scheduled, and a detailed document evaluation checklist having beendeveloped. Test activities may include, without limitation: (1) collectall appropriate information; (2) perform interviews and reviewdocumentation; (3) evaluate the quality of the ILEC's M&R documentation;(4) complete the evaluation checklist and interview summaries; and (5)develop and document findings. Exit criteria may be limited to globalexit criteria. The ILEC's M&R documentation reviewed may include, forexample, internal ILEC documents, CLEC “handbooks,” CLEC “studentguides,” or any other suitable documents. The interviewees arepreferably SMEs with direct responsibility for and knowledge of targeteddocumentation. CLEC representatives may also be interviewed to validatevarious observations made during other parts of the test.

Test target areas and their associated evaluation measures aresummarized in the table below. The last column of the table indicateshow evaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria M & R documentation MRTAS reference Adequacy of procedures for1-5 documentation for CLECs addressing document production,distribution, revision, and quality control Structure and format ofdocument 6-9 Content in terms of clarity, 10-18 accuracy, completenessMRTAS on-line help Structure and format of document 21-22 Content interms of clarity, 19-20 accuracy, completeness CLEC handbook Structureand format of document 23-29 (M & R sections) Content in terms ofclarity, 30-36 accuracy, completeness CLEC student guide Structure andformat of document 23-30 (M & R sections) Content in terms of clarity,31-36 accuracy, completeness Management of M & R Adequacy of proceduresfor 37-43 documentation generally addressing document production,distribution, revision, and quality control

Evaluation criteria relating to MRTAS reference documentation mayinclude one or more of the following, in any combination and withoutlimitation:

Document Management: (1) responsibilities and procedures for developing,updating, and correcting documentation are clearly defined; (2)responsibilities and procedures for maintaining distribution lists andfor distributing documentation are clearly defined; (3) distributionprocedures allow latest versions of documentation to be made availableto interested parties in timely manner; (4) training is provided for useof documentation; and (5) ILEC 14 provides methods for CLECs 16 toindicate errors or omissions in documentation.

Document Structure and Format: (6) version is indicated in each documentand is clear throughout document; (7) documentation providescross-references and has clear citations directing readers to relevantsources of additional information; (8) documentation indicates scope andpurpose; and (9) the documentation is logically organized (e.g., clearpage numbering and section labeling, table of contents, glossary ofterms, explanation of acronyms, etc.).

Document Content: (10) the documentation describes how to access MRTASrelated systems; (11) the documentation clearly defines how to navigatethe MRTAS related systems (e.g., use of screens (masks)); (12)documentation defines data entry fields for creating, checking status,modifying, and closing trouble tickets; (13) the documentation definesdata entry fields for diagnostic testing; (14) documentation explainsthe acceptable formats for data fields; (15) the documentationdistinguishes between required and optional fields; (16) documentationdefines possible options after data entry (e.g., save, send, cancel,etc.); (17) documentation describes expected system responses andoutputs; and (18) documentation provides descriptions of error messagesand possible steps for resolution.

Evaluation criteria relating to the MRTAS on-line help facility mayinclude one or more of the following, in any combination and withoutlimitation: (19) the facility defines data entry fields for diagnostictesting and creating, checking status, modifying, and closing troubletickets; (20) the facility provides descriptions of error messages andpossible steps for resolution; (21) user navigation guides are providedas part of or in association with the facility; and (22) the facilityprovides cross-references to other sources for completeness.

Evaluation criteria relating to CLEC handbooks or CLEC student guidesmay include one or more of the following, in any appropriate combinationand without limitation:

Document Structure and Format: (23) the documentation states the scopeand purpose of M&R activities; (24) the documentation is logicallyorganized (e.g., clear page numbering and section labeling, table ofcontents, glossary of terms, explanation of acronyms, etc.); (25) thedocumentation describes M&R sub-processes for which it is applicable;(26) documentation provides M&R contact list; (27) documentationprovides cross-references to other sources for completeness; (28) thedocumentation provides procedures for the CLECs 16 to submit correctionsor omissions; and (29) CLEC training is offered with documentation.

Document Content: (30) the documentation adequately describes the M&Rprocess; (31) the documentation includes M&R process map; (32) thedocumentation contains methods and procedures to execute the M&Rprocess; (33) the documented methods and procedures contain enoughdetail and clarity to execute M&R process; (34) the documentationincludes expected results of the M&R process and its cycle time; (35)the documentation describes the exception handling process and providescontact information for unusual occurrences; and (36) the documentationidentifies suppliers and customers (inputs/outputs) of the M&R process.

Evaluation criteria relating to the management of M&R documentation mayinclude one or more of the following, in any combination and withoutlimitation: (37) responsibilities and procedures for maintainingdistribution lists and for distributing documentation are clearlydefined; (38) documentation is distributed in a regular and timelyfashion, ensuring that all process and procedural changes are captured;(39) training is provided along with documentation; (40) thedistribution procedure allows latest document version to be madeavailable to interested parties in electronic and paper versions in atimely manner; (41) responsibilities and procedures for developing andupdating documentation are clearly defined; (42) document versionannotations are clearly visible on the documentation and areconsistently applied; and (43) the responsibilities and procedures forcorrecting errors made during M&R document production are clearlydefined.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

G. M&R Help Desk Test

This test provides a comprehensive operational analysis of ILEC helpdesk processes supporting CLECs 16 with questions, problems, and issuesrelating to the M&R Domain activities. For example, the help desk mayreceive trouble calls from CLECs 16, may support CLECs 16 as to issuesrelating to trouble reports that have already been submitted, and mayanswer CLEC questions relating to M&R issues. The M&R help desk may bewholly or partially integrated with POP Domain help desk 50 describedabove and may refer CLECs 16 to other SMEs outside the help desk ifappropriate. This test may evaluate the functionality, performance,escalation procedures, management oversight, security, or other aspectsof the help desk.

In a particular embodiment, the test includes two parts: (1) proceduralreview of ILEC procedures for performing and managing help deskfunctions; and (2) an analysis of help desk performance based uponinteraction between pseudo-CLEC 18 and the help desk during M&R Domaintesting described more fully above. For the procedural evaluation,operational analysis techniques are used. The testing entity generatesevaluation checklists to facilitate structured walk-throughs of the helpdesk processes and interviews with help desk personnel and management todiscuss these processes. The testing entity also reviews ILECdocumentation and may solicit input from CLECs 16 as to the ILEC's helpdesk performance.

Observations made during structured walk throughs of the ILEC help desk,structured interviews, and reviews of process documentation andhistorical call logs provide the primary sources of data for this partof the test. Walk throughs may provide the testing entity with afirst-hand understanding of the responsibilities and performance of helpdesk personnel. ILEC process documentation provides further insight intothe ILEC's operational processes. Historical call logs should allow thetesting entity to assess the root cause of issues and the accuracy andtimeliness of ILEC responses. Observations and interviews of appropriateCLEC personnel may increase knowledge as to help desk processes, providean understanding of CLEC expectations for M&R support, and highlight M&Rprocesses for scrutiny.

Observation targets for the walk-throughs may include, withoutlimitation: (1) help desk logs containing information relating to helpdesk inquiries received; (2) contact information for certain help deskor management personnel; (3) an electronic “suggestion box” possiblyassociated with MRTAS interface 142 for receiving CLEC input; (4)read-only viewing of HTML pages or other files presented to CLECs 16 inassociation with MRTAS interface 142, for example, to verify thatappropriate error messages are conveyed to CLECs 16; and (5) a trainingpacket or other appropriate reference documentation that provides helpdesk personnel with descriptions of the error messages that may begenerated and basic problem solving techniques to be used in relation toeach such error message.

CLEC participation may be solicited in several ways. In one embodiment,CLECs 16 receive surveys requesting feedback on particular interactionswith the help desk concerning M&R Domain issues. As an example, thetesting entity may record the particular help desk (of possibly multiplehelp desks) that the CLEC 16 contacted, the CLEC's description ofprocedures ILEC 14 followed in responding to issues, and the CLEC'squalitative assessment of the level of support that ILEC 14 provided. Inaddition, CLECs 16 may be invited to participate in walk-throughs, toobserve CLEC interaction with the help desk, to participate in relateddiscussions, or to have other suitable involvement.

The performance evaluation relies on qualitative and quantitativeanalysis of selected data collected during M&R Domain transactiontesting. In one embodiment, the testing entity establishes its own helpdesk within pseudo-CLEC 18 to interface with the ILEC's help desk. Whenissues arise during transaction testing, testers may direct theirinquiries to the pseudo-CLEC help desk, which in turn places calls tothe ILEC help desk to evaluate its performance in terms ofresponsiveness, timeliness of resolution, and accuracy of resolution.Interactions with the help desk are logged, typically including the datethe issue was referred to the help. desk, the particular trouble report(if any) and issue, the outcome, the resolution date if any, and anerror reason assigned following issue resolution. If immediateresolution is not achieved, the issue status may be tracked untilresolution. Once a resolution is received at the pseudo-CLEC's helpdesk, it is communicated to a tester who may then take any appropriateaction. To evaluate the ILEC's help desk performance, information in theissue logs is analyzed and organized by type or otherwise. In addition,interviews with pseudo-CLEC help desk personnel regarding theirqualitative experience with the ILEC's help desk may be conducted.

Where MRTAS interface 142 is unavailable, M&R activity may instead beinitiated by calling the ILEC help desk, where help desk personnelmanually create a trouble ticket. Responsibility for the trouble ticketmay then be transferred to ILEC personnel who identify the type oftrouble and the affected network element, verify that the trouble ticketwas entered correctly, and manage the M&R process to closure. Help deskpersonnel may access historical information about closed trouble ticketsin performing these duties. Help desk personnel may also be tasked withcoordinating M&R activities among the ILEC's technicians, CLECtechnicians, and the help desk itself.

Test target areas and associated evaluation measures are summarized inthe table below. More specific evaluation measures may be used toevaluate test target areas that pertain to specific trouble reporting orother M&R activities. The last column of the table indicates how theevaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria Call processing Documentation Clarity, accuracy, and  1-3completeness Call answer, logging, and Existence, timeliness, and  1-2,4-10, prioritization accuracy 14-15 Problem tracking and DocumentationClarity, accuracy, and  1-3 resolution completeness Identify and resolveTimeliness and accuracy 1, 5, 18 Track problem, log status, Existence,timeliness, and  1-2, 11 close trouble ticket, and accuracy notify CLECExpedite and escalation Documentation Clarity, accuracy, and  1-3procedures completeness Identify and resolve Timeliness and accuracy 1,5, 12-13, 18 Track problem, log status, Existence, timeliness, and  1-2,11, 14 close trouble ticket, and accuracy notify CLEC Help deskprocedures Clarity, accuracy, and  1-2, 4, 11, 13, in generalcompleteness 16-19

Evaluation criteria for this test may include one or more of thefollowing, in any combination and without limitation: (1) help deskprocess responsibilities and activities are clearly defined andunderstood; (2) the scope and objectives of the help desk process areclearly defined and understood; (3) a substantially complete (i.e.beginning-to-end) description of help desk process is clearly defined;(4) standard procedures are in place to handle with CLEC trouble calls;(5) help desk personnel know how to handle CLEC inquiries; (6) help deskpersonnel are aware of the ILEC procedures for logging trouble calls;(7) each trouble call is logged; (8) trouble calls are categorized intovarious types with standard responses for each type; (9) the help deskidentifies and tracks the number of each different type of trouble; (10)the help desk tracks the number of repeat trouble calls; (11) the ILECM&R technicians and help desk supervisors have processes for trackingvarious types of reported troubles; (12) help desk personnel know whento escalate complaints to a supervisor; (13) the help desk processincludes handling of expedites and escalations; (14) the escalatedtrouble calls are logged in an acceptable format; (15) the troubleticket entry process includes procedures for addressing any errors andexceptions made by the help desk personnel; (16) process performancemeasures are defined and measured; (17) the responsibilities fortracking performance are assigned to management personnel; (18) helpdesk process includes identifying and resolving CLEC problems; and (19)help desk process includes appropriate security measures.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

H. M&R Network Surveillance Support Test

This test evaluates the network surveillance and network outagenotification processes and the associated operational elements of theILEC 14, comparing these capabilities for the ILEC's wholesale productswith those for retail counterparts sold to CLECs 16. ILEC 14 typicallyimplements its network surveillance and network outage notificationprocesses using one or more NOCs or the like.

In one embodiment, network elements available for sale to CLECs 16 andevaluated in this test may include, for example, inter-office facilities(IOFs) between COs, dedicated trunk ports on unbundled ILEC switchesconnecting them to CLEC collocations, Intelligent Network (IN)components, SS7 or other signaling links, and other suitable networkelements. In general, outages are the result of unusual events,conditions, or situations that affect (or may be expected to affect)ILEC equipment, service capability, or personnel. The test contemplatesILEC 14 using any suitable systems to monitor its network, theconstituent network elements, and appropriate associated capabilities.

Entrance criteria for the test may include all global entrance criteriahaving been satisfied, an appropriate test-specific interview guide orquestionnaire having been developed, interviewees having been identifiedand scheduled, documentation having been obtained for all outagenotification and network surveillance processes for wholesale, and adetailed evaluation checklist having been developed. The test activitiesmay include, without limitation: (1) collect all appropriateinformation; (2) review documentation, including any network outagenotification and related trouble administration documentation and CLECreference documentation (e.g., to determine the degree of compliancewith service level agreements); (3) perform interviews of ILECpersonnel; (4) conduct operational analysis at ILEC NOCs or otherrelevant facilities, observing ILEC network surveillance and outagenotification procedures; (5) complete the evaluation checklist andinterview summaries; (6) interview CLEC personnel to validate theconclusions developed during the test; and (7) develop and documentfindings in report. Exit criteria may be limited to global exitcriteria.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria Network Surveillance Existence 1 surveillance of appropriateand reliability network elements Outage Outage process Clarity,accuracy, 2 notification documentation and completeness NotificationTimeliness, accuracy, 3 procedures and completeness

Evaluation criteria for this test may include one or more of thefollowing, in any combination and without limitation: (1) surveillanceexists and is reliable; (2) documentation is clear, accurate, andcomplete; and (3) procedure is timely, accurate, and complete.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

I. M&R CLEC Coordination Test

This test evaluates ILEC procedures associated with meetings and othercoordination activities between the ILEC 14, one or more CLECs 16, andpossibly third party vendors relating to M&R operations. For example,such joint meetings might be needed to resolve chronic issues, conductjoint activities on ILEC switch circuits, isolate faults that aredifficult to locate, verify diagnoses relating to current troubles, orotherwise rectify complicated M&R issues. Joint meetings may take placeat any location within or outside an ILEC CO. In one embodiment, disputeresolution, escalation, consistency of M&R activities, and coordinationwith third parties are primary aspects evaluated. Sources of data forthis test may include observation of joint meetings and othercoordination activities, and interviews with ILEC, CLEC, and third partypersonnel involved in these activities. Interviews may be beneficial toestablish facts and gain a better understanding of the purpose of thejoint meetings, current meeting procedures, and the effectiveness of theprocedures. Any appropriate ILEC documentation may also be reviewed.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria Joint meet Process Clarity, accuracy, 2 proceduresdocumentation and completeness Notification Timeliness 1, 3-17procedures and accuracy Coordinated Process Clarity, accuracy, 2 testingdocumentation and completeness Notification Timeliness 1, 3-17procedures and accuracy

Evaluation criteria for this test may include one or more of thefollowing, in any suitable combination and without limitation: (1)suitable procedures for M&R coordination are in place; (2) the jointmeeting procedures are documented; (3) joint meetings occurinfrequently; (4) the responsibilities for scheduling joint meetings areclearly defined; (5) joint meetings are conducted with fully qualifiedILEC M&R personnel; (6) ILEC coordination personnel are familiar withand have received the appropriate training relating to any ILEC networkelement needing attention; (7) all equipment training coordinationpersonnel receive is certified to ILEC standards; (8) joint meetings areconducted when important M&R issues must be jointly resolved (i.e.issues that, if not rectified quickly, can seriously hinder the abilityof a CLEC 16 to provide service to its customers); (9) ILEC coordinationpersonnel have sufficient seniority to handle joint meetings with CLECs16 and/or third party vendors; (10) ILEC 14 ensures that the appropriateSMEs from CLECs 16 participate in the joint meetings; (11) jointmeetings lead to reasonably timely solutions that do not result in longdown time for customers of CLECs 16; (12) joint meetings occur in thecorrect locations; (13) the majority of joint meetings do not lead toescalations to higher management (i.e. are resolved at the coordinationlevel); (14) third party vendors, when participation is appropriate, areinformed of the location, time, and nature of joint meeting; (15) thirdparty vendors do not hinder the successful resolution of the jointmeeting; (16) chronic issues do not require repeated joint meetings; and(17) the ILEC's joint meeting process includes identifying and resolvingtroubles that initially are not clearly associated with ILEC or CLECequipment.

Billing Domain

The general purpose of testing within the Billing Domain is to evaluatethe systems, processes, and other operational elements associated withthe ILEC's support of certain billing activities affecting its wholesalecustomers—CLECs 16. Billing Domain testing is designed to evaluate theaccuracy and timeliness of billing related information that ILEC 14provides to CLECs 16, evaluate the ability of ILEC 14 to provide supportfor CLEC billing operations, and evaluate the ILEC's compliance withmeasurement agreements. The report generated by the testing entityshould preferably allow the regulatory entity to assess the net impactof Billing Domain issues that it identifies on the ability of CLECs 16to operate in an open competitive environment for localtelecommunications services in the particular jurisdiction of interest.

In one embodiment, the Billing Domain is broken down into a number ofprimary test target areas that may include, without limitation, billingmetrics, billing documentation, billing help desk support; daily usagefeed (DUF), and carrier bills. Each primary test target area may befurther broken down into increasingly discrete process and sub-processareas that identify the particular areas to be tested and the types ofmeasures that apply to each area. According to the present invention,tests have been developed to evaluate each test target area based on thescope of testing to be performed in each of the areas. Particularexample process and sub-process areas for each test target area, withexample associated evaluation measures and evaluation criteria, aredescribed in more detail below.

There need not be a one-to-one correspondence between test target areasand specific tests. In one embodiment, Billing Domain tests may includeone or more of the following, without limitation: (1) Process MetricsTest, (2) Documentation Test, (3) Help Desk Support Test, (4) ResaleBill Certification Process Test, (5) Usage Returns Process Test, (6)Functional Usage Test, and (7) Functional Bill Cycle Test. Exampleembodiments of these tests are described in detail below.

Some of the tests are transaction-based, involving the creation andprocessing of predefined transactions (e.g., usage test calls and POPscenarios). In general, transaction-based tests are designed toestablish a structured operational environment for submission ofbilling-related transactions and, using this environment, to assesswhether CLECs 16 receive accurate, complete, and timely billinginformation. For example, billing-related information may include usageflowing through the ILEC's billing process and onto a CLEC's DUF,billing charges flowing through the ILEC's billing process and onto aCLEC's bill, or any other suitable information. Other tests areprocess-based, involving walk-through inspection of ILEC operationalprocesses and practices, structured review of the ILEC's procedures andrelated documentation, structured interviews with ILEC SMEs, or othersuitable information. One or more tests may include bothtransaction-based and process-based aspects. Billing Domain testing mayimplement a “black box” testing approach that is not concerned with thebehavior or structure of internal component, but is instead focused onwhether input information appears accurately on the outputs (e.g., DUFsand carrier bills).

A. Billing Process Metrics Test

This test provides an end-to-end operational analysis of the systems andprocesses ILEC 14 uses to generate wholesale billing information andcommunicate that information to CLECs 16. The objectives of the test areto evaluate the billing metrics ILEC 14 uses, the method ILEC 14 usesfor determining metric values, and the ILEC's dissemination of metricvalues to CLECs 16. In one embodiment, the test focuses primarily on twosuch billing metrics: (1) DUF timeliness, and (2) carrier billtimeliness. Both are used to evaluate the quality of the ILEC's serviceto CLECs 16, which in turn use the DUF and carrier bill data to billtheir own customers.

This test was developed to evaluate the validity (in terms ofcompleteness, applicability, and security) of measurements correspondingto these billing metrics and to assess the strength of procedures anddocumentation supporting the taking of these measurements. Arrangementsare preferably made with ILEC SMEs to walk through the relevantprocedures such that the testing entity can fully evaluate theseprocedures. The walk-throughs for the DUF and carrier bill timelinessmetrics may be performed concurrently or in any order. Summaries ofthese walk-throughs are preferably created and circulated to ILEC 14 andto the regulatory entity.

In one embodiment, processing of the DUF and carrier bill timelinessmetrics includes the following common steps, without limitation (1)acquiring data from the usage processing and billing systems, (2)processing this usage and billing data to develop the results, and (3)distributing the data and the results. The data collected is analyzed inreference to the evaluation criteria provided below.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures Evaluation Process Area Sub-Process AreaEvaluation Measures Criteria Validate metrics Identify control pointswhere Applicability and  3-4, 11 information gathering measurements aretaken measurability of control points process Identify data sources foreach Applicability and 3, 5-6, 9, 11 reported metric completeness ofdata sources Identify each tool used by Applicability and reliability 5-6, 9, 11 ILEC to collect data of tools Evaluate quality of Evaluatecalculation Accuracy and applicability of  6-7, 9-11 metric reportedcalculations Evaluate tools Accuracy, security and  5-7, 9, 11controllability of data housed in tools Evaluate reports Evaluate reportformat Consistency of reporting 12-13 results with data collectedEvaluate report content Accuracy of metrics reporting 12-13

Evaluation criteria may include the following, without limitation. Thesame evaluation criteria may be used for both DUF and carrier billevaluations.

Definitions: (1) the purpose of taking the metric is defined; and (2)the metric and the conditions under which it is applicable arespecified.

Measurement Process: (3) the location at which the measurement is takenis defined; (4) the time at which the measurement is taken is defined;(5) the hardware, software, and other instrumentation for taking,processing, and communicating the measurement are defined; (6) steps fortaking, processing, and communicating the measurement are defined; and(7) the mathematical and statistical algorithms to be applied aredefined.

Performance Standards and Norms: (8) the desired level of attainment forthe metric is identified; (9) the measures of attainment are reviewedfor accuracy on a timely basis; (10) the persons responsible forachievement of performance standards are identified; and (11) proceduresfor making changes to the metric or performance standard are defined.

Publication and Distribution: (12) the measurement results are publishedand distributed, and (13) the published results are readilyunderstandable.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

B. Billing Documentation Test

This test provides an operation analysis of the billing documentationCLECs 16 use to accept and process the DUF and carrier bill output theyreceive from ILEC 14. ILEC 14 will typically provide wholesale customerswith certain documentation regarding its billing procedures, billcontent, and related interactions with ILEC 14. The primary repositoriesfor this documentation are typically handbooks, which may be acquiredfrom ILEC 14 through a website or otherwise. The purpose of this test isto evaluate the quality of ILEC documentation and to determine how wellit supports ILEC customers in pursuit of their own business interests.

In one embodiment, this test includes two sub-tests. The first evaluatesthe processes and procedures by which ILEC 14 produces billingdocumentation. The basis for this sub-test is the idea that consistentproduction of quality documentation will be unlikely unlesswell-defined, comprehensive, and well-managed production processes arein place. This procedural sub-test may be conducted according to aprocess evaluation checklist that contains evaluation criteria forprocesses governing document production.

The second sub-test relies on an independent document evaluation by thetesting entity. Although this may well introduce additional subjectivityinto the test, the personnel evaluating the billing documentation havepreferably been users of the documentation in constructing and carryingout various other billing and usage tests described below, and aretherefore well positioned to make such judgements. This sub-test may beconducted in one or more sessions.

In one embodiment, the test process proceeds as follows. First, a listof the required billing and usage topical coverage requirements isdeveloped. Such topical areas may include, without limitation: (1)validating bills; (2) validating usage; (3) processing credits,adjustments, and usage returns; (4) primary billing operations andsupporting technical information; (5) contact information for help onbilling issues; and (6) miscellaneous billing documentation such asforms, glossaries, and certain industry mailings.

Second, ILEC documentation concerning billing procedures is reviewed foreach of the topical areas. This may include handbooks, industrymailings, and any other suitable documentation.

Third, ILEC documentation is evaluated for topical coverage, usability,and accuracy. Specific evaluation criteria are preferably developed inthese categories. The evaluation of topical coverage may involveevaluating the breadth and depth of processes, explanations, and datadefinitions in the documentation. Evaluation of usability may involveevaluating the organization and flow, references and indexes, and styleof documentation. Evaluation of accuracy may involve creating a list of“errors” that provide examples of where and how the documentation doesnot agree with practice.

Fourth, evaluation findings are recorded for each content coveragecategory. The data collected is then analyzed in reference to theevaluation criteria provided below. As described above, a test result of“Satisfied” is assigned to an evaluation criterion if no deficienciesare observed. A result of “Satisfied, with qualifications” or anothermore negative result may be assigned if deficiencies were observed. Theextent to which documentation deficiencies may result in serious adversebusiness impact, and may therefore give rise to an exception, isaddressed below in connection with the transaction-based Billing Domaintests. Instances where ILEC billing and usage documentation conflictswith actual findings (i.e. “errors”) may be noted as a furtherindication of billing documentation quality, possibly without generatinga test result or further investigating the source of the discrepancy.

Finally, an overall summary of the billing documentation review testresults by topical area is developed.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria Acquire documentation Receive current Availability ofup-to-date 1 documentation documentation Evaluate documentation Evaluatedocumentation Organization of 7 format documentation Ease of use ofdocumentation Evaluate documentation Comprehensiveness of 1-6 contentdocumentation Accuracy of documentation

Evaluation criteria for this test may include one or more of thefollowing, in any combination and without limitation: (1)responsibilities of ILEC personnel and procedures for developing,updating, correcting, and distributing documentation are clearlydefined; (2) responsibilities of ILEC personnel and procedures forensuring quality documentation are clearly defined and documented; (3)the procedures are carried out in compliance with the ILEC's internaldocumentation; (4) step-by-step instructions for are provided forcustomers to interact with ILEC 14; (5) explanations are provided forcustomers to use where interaction with ILEC 14 is not required; (6)definition, format, medium, and applicable standards are provided fordata elements; and (7) the usability, organization and flow, navigationand reference, and style are acceptable. Within each primary evaluationcriterion, the topical areas described above may be evaluated.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

C. Billing Help Desk Support Test

This test provides an operational analysis of the ILEC's help deskprocesses supporting CLECs 16 with respect to their usage-related andbilling-related issues. The test evaluates the ILEC's key billingsupport process elements, including the receipt, processing, monitoring,escalation, and management of claims and of help desk calls involvingquestions, problems, or other issues. The scope of the servicesevaluated may include, without limitation: (1) responding to customerquestions and problems regarding ILEC-provided usage and billinginformation, and (2) evaluating and processing customer requests forusage adjustments and billing corrections. The ILEC billing help deskmay be wholly or partially integral to help desk 50 described above inconnection with POP Domain testing or the help desk described above inconnection with M&R Domain testing.

In one embodiment, this test includes two sub-tests. The first evaluatesthe ILEC processes used to provide help desk services. This proceduralevaluation will preferably focus on ILEC processes for initiating,processing, closing, tracking, and managing customer requests forinformation, adjustments, and corrections. A “walk-through” of relevantprocedures is preferably conducted with ILEC SMEs. Since the billinghelp desk responsibilities for resale and UNE offerings may potentiallybe vested in separate organizations within ILEC 14, separatewalk-throughs may need to be conducted depending on the internalstructure of ILEC 14.

The second sub-test involves placing test calls to the help desk toprovide an understanding of the effectiveness and integrity of theprocesses described above. The test questions may be formulated toinclude some general procedural and policy questions in addition to morespecific questions drawn from the actual usage records and carrierbills. This sub-test is designed to evaluate: (1) accessibility of theILEC help desk function (i.e. timeliness of call answer); (2) timelinessof the response (i.e. interval between initial question and finalresponse); and (3) the quality of the ILEC response (i.e. how well theresponse matches or can be reconciled with the expected response).Questions may be determined in part using CLEC input solicited usingstructured questionnaires distributed to CLECs 16, in which CLECs 16 areasked to provide recent inquiries. A standard set of questions to beplaced to the ILEC help desk may be formulated in any suitable manner.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures

Process Areas Sub-Process Areas Measures Criteria Receive help deskAnswer call Timeliness of call 1-2, 6-7, call 36 Interface with userAvailability and usability of 1-3, 7 interface Log call Existence andaccuracy of call 1-2, 6-7 logging Record severity code Compliance ofcall logging - 1-2, 8 severity coding Process help desk Resolve userquestion, Completeness and consistency 1-2, 5-9, call problem or issueof process 11, 13, Accuracy of response 36-38 Receive claim File claimCompleteness and consistency 1-2, 29, of process 32 Accuracy of responseProcess claim Completeness, consistency, 1-2, 30- and timeliness ofprocess 31, 36-38 Issue adjustment, when Completeness an consistency1-2, 30- necessary of process 31 Disposition claim Accuracy,completeness, and 1-2, 30- reliability of disposition report 31, 35Close help desk call Post closure information Completeness, consistency,1-2, 11, and timeliness of process 27, 30, Accuracy of posting 35Monitor status Track status Existence of status tracking 1-2, 27,capability 33-34 Consistency and frequency of follow-up activitiesAvailability of jeopardy notification Report status Completeness andconsistency 1-2, 12- of reporting process 13 Accuracy and timeliness orreport Accessibility of status report Request escalation Identifyescalation Existence of procedure 1-2, 15 procedure Evaluate escalationCompleteness and 1-2, 14, procedure consistency of process 21-28 Manageworkforce Identify work force Existence of procedure 1-2, 15 capacityplanning procedures Evaluate work force Completeness of procedure 1-2,15 planning procedures Review staffing plans Scalability of staff volume1-2, 15 Provide security Provide secured Completeness and 1-2, 16 andintegrity access applicability of security procedures, profiles, andrestrictions Controllability of intra- company access Manage help deskProvide management Completeness and consistency 1-2, 11- processoversight of operating management 14, 17- practices 20, 27-Controllability, efficiency and 28, 35 reliability of processCompleteness of process improvement practices

Evaluation criteria for the second sub-test may include one or more ofthe following, in any suitable combination and without limitation:

Procedural Consistency and Clarity: (1) responsibilities and activitiesare clearly defined; (2) scope of help desk services covers key CLECrequirements; (3) scope and objectives of help desk are clearly defined,documented, and communicated to CLECs 16; (4) a complete (i.e.beginning-to-end) description of help desk process is documented; (5)help desk process includes procedures for addressing errors andexceptions; (6) help desk process includes procedures for resolvingissues in timely and efficient manner; (7) the help desk processincludes complete and consistent call intake procedures (i.e. loggingand acknowledgement); (8) help desk process defines criteria andprocedure for severity coding help desk calls; (9) the help desk processincludes procedures for referral and tracking of referral (in and out ofthe help desk); (10) the help desk process includes complete andconsistent procedures for jeopardy notification; (11) help desk processincludes complete and consistent procedures for closure posting; (12)help desk process includes complete and consistent procedure for statustracking and management reporting; (13) the help desk process includescomplete and consistent procedure for documenting unresolved help deskcalls; (14) help desk process includes complete and consistent procedurefor escalating issues and problems; (15) the help desk process includescomplete and consistent procedure for capacity planning; and (16) thehelp desk process includes procedures to maintain security and integrityof data access controls.

Performance Measurement and Reporting: (17) the help desk processincludes procedures for obtaining CLEC feedback on effectiveness of helpdesk; (18) the help desk process performance measures are defined andmeasured; (19) responsibilities for tracking performance are assigned;and (20) the help desk process improvement procedures are defined andresponsibilities assigned.

Escalation Specific Scope: (21) overall escalation flow proceduresexist; (22) each step has one or more associated criteria forescalation; (23) each step has one or more responsible parties anddocumented contact information; (24) the information requirements andinformation transmission for each step are defined; (25) each step hasdocumented time limitations or parameters; (26) the problem submitter iskept informed of progress, lack of progress, and issues affectingresolution; (27) problem status is tracked and tracking information isreadily accessible; and (28) an escalation process owner is responsiblefor overall performance and improvement.

Adjustment Specific Scope: (29) the procedures for accepting anyadjustment requests are documented; (30) help desk process includescomplete and consistent procedures for issuing adjustments; (31) theresponsibilities, process routing, process intervals, and adjustmentauthorization levels are defined and documented; (32) the adjustmentrequests and transmission requirements are suitably documented and arereadily available to CLECs 16; (33) CLECs 16 have convenient access tostatus of adjustment requests; (34) CLECs 16 are proactively notified ofthe status of schedule changes and corresponding reasons or open issues;and (35) escalation procedures beyond the help desk (i.e. to accountmanagement and beyond) are well defined and documented.

Evaluation criteria for the second sub-test may include one or more ofthe following, in any suitable combination and without limitation: (36)the timeliness of call answer—whether responsible ILEC representative isreached on initial call, reached on call back or follow-up in aspecified time period, reached according to some other satisfactoryarrangement, reached otherwise, or not reached at all; (37) timelinessof response—whether response is returned during call, response or anacknowledgment with a justifiable due date is returned in a specifiedtime period, neither response nor an acknowledgment is received inspecified time period or due date is not justifiable, or response is notreceived; and (38) quality of the answer—whether the response matchesthe expected response in substantially all respects or wherediscrepancies exist a full explanation is provided, the response hadminor un-addressed or unclear elements but would be generally acceptableto a customer, or response either is not provided or did not addressissue or would not be generally acceptable to a customer.

Since relevant industry performance standards or norms may not bedefined, evaluation criteria for the second sub-test may be definedbased on certain help desk considerations deemed generally appropriatein a variety of environments. For this reason, however, results arepreferably considered only in conjunction with findings made during thefirst sub-test described above.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

D. Billing Usage Returns Test

This test is an analysis of the procedures and related documentationthat the ILEC 14 uses to process usage returns. A CLEC 16 may returnusage when usage records received on DUFs are believed to containerrors. Returning usage is a sub-process of the broader usage claimsprocess. If a CLEC 16 believes one or more usage items contain errors,CLEC 16 may initiate a usage claim. ILEC 14 may then be obligated toresolve the claim by correcting the usage, issuing an adjustment, ordetermining that the claim is not valid. ILEC 14 might require CLEC 16to transmit the erred usage back to ILEC 14 with reason codes so thatILEC 14 can investigate the errors. The procedures ILEC 14 follows inthe United States may be generally described in the Exchange MessageInterface (EMI) guidelines of the Ordering and Billing Forum (OBF).However, as noted above, ILEC 14 may be any incumbent carrier in anyappropriate jurisdiction.

The processes differ depending on the nature of the claim. In a firstcase, CLEC 16 determines that the DUF contains duplicate records,invalid records, or records with invalid or incorrect data. In thiscase, CLEC 16 may be responsible for notifying ILEC 14, repackaging theerred records (including the original headers and trailers), andreturning these records to the ILEC 14. CLEC 16 may also need to adjustfields on each returned record to indicate that the record is beingreturned and the reason for the return. The fields that may need to bechanged and their possible values are described, for example, in the EMIguidelines. If CLEC 16 has already processed the records with allegedlyincorrect data, ILEC 14 may be obligated to investigate and resolve theerred records within two weeks of receipt. If the claim is resolved inthe CLEC's favor, ILEC 14 either issues a billing adjustment or sends aseries of records that correct the error. These records typicallyinclude records that nullify the previous charges and records thatcorrect the charges. These records are commonly known as “killerrecords,” and are described in the EMI guidelines. If a claim is notresolved to the CLEC's satisfaction, CLEC 16 may escalate the claim asappropriate.

A second case occurs when the usage charge amount is in dispute. In thiscase, a claim may need to be filed. Depending on the size and severityof the claim, ILEC 14 may require usage to be returned in order toprocess the claim. If the claim is resolved in the CLEC's favor, acorrection may be issued on the CLEC's bill, for example, as an “OtherCharge and Credit”. CLEC 16 has full discretion as to how it willtransfer this correction to its overcharged customer. If a claim is notresolved to the CLEC's satisfaction, CLEC 16 may escalate the claim asappropriate.

In one embodiment, this test includes a procedural sub-test and atransaction-based sub-test. For the procedural sub-test, arrangementsare preferably made for ILEC SMEs to “walk through” the relevantprocedures with testing entity personnel. A summary of the walk-throughmay be created and circulated to ILEC 14 and the regulatory entity. Thetransactional sub-test traces the activities that occur when a CLEC 16makes a usage claim that requires usage to be returned, to assesswhether the ILEC procedures described during the procedural sub-test arein fact followed in practice. The data sources for this test may includeILEC walk-through participants, suitable walk-through documentation, andusage data generated during execution of the Billing Functional UsageTest described below. CLEC input may be solicited as appropriate.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures

Process Areas Sub-Process Areas Measures Criteria Usage return ILECreceives erred Clarity and complete- 1-4, 7-9, process usage ness ofusage 16 return procedures ILEC sends Accuracy, complete- 1-6, 11-corrections when ness, and timeliness 14, 17-18 necessary of correctionsILEC provides item Accuracy, timeliness, 10, 15, status for all andcompleteness 17 returned records of status report

Evaluation criteria for the procedural sub-test may include one or moreof the following, in any suitable combination and without limitation:

Procedural Consistency and Clarity: (1) scope and objectives of theprocess are clearly defined; (2) the responsibilities for carrying outthe process are clearly assigned; (3) a complete (i.e. beginning-to-end)description of the process is defined; and (4) the procedure forprocessing usage returns is documented.

Performance Measurement and Reporting: (5) suitable process performancemeasures are defined and measured; (6) responsibilities for trackingperformance are assigned; (7) ILEC 14 assists CLECs 16 with submittingusage returns; (8) incoming requests are logged and any necessarytrouble tickets are opened; (9) investigation procedures arecommunicated to CLECs 16; (10) CLECs 16 are kept informed of status;(11) usage complaints are investigated using a process with built inquality control components; (12) usage complaints are responded to; (13)the ILEC 14 sends corrected records to the CLECs 16 when necessary; (14)the ILEC 14 issues billing adjustments when necessary; and (15) troubletickets are closed when appropriate.

Evaluation criteria for the transactional sub-test may include one ormore of the following, without limitation: (16) the ILEC 14 assists CLEC16 with returning usage and accepted the returned usage; (17) ILEC 14follows established procedures in investigating and resolving claims;and (18) resolution was appropriate.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

E. Billing Functional Usage Test

This test provides an operational and systems analysis of the ILEC'sability to process usage such that the usage appears on the DUFsprovided to CLECs 16 in a timely and accurate manner.

Usage charges typically represent an important source of revenue forCLECs 16. Usage information is recorded at the usage port of a switch. Afacilities-based CLEC 16 may own the usage port, in which case CLEC 16records usage information without any ILEC involvement. When ILEC 14owns the usage port, however, as in resale and UNE situations, ILEC 14records usage information. This test looks at the second situation,where ILEC 14 is responsible for providing a copy of the usageinformation to CLECs 16 in a timely and accurate manner. In oneembodiment, at least for purposes of this test, the testing entityestablishes two test CLECs in the ILEC's production environment—oneproviding resale services and one providing UNE services. These testCLECs may be the same as or different than the pseudo-CLEC 18, in wholeor in part. The ILEC's switches generate events as they process calls.Such calling information is recorded in a file and, each day, ILEC 14receives calling information from its switches. If calling informationis for calls billable to a wholesale customer such as a CLEC 16, or ifthe calling information includes Inter-Exchange Carrier (IXC) accessrecords, a DUF file is created. The ILEC 14 typically creates a DUF foreach CLEC 16 and delivers the DUFs to CLECs 16 using cartridge tapes orappropriate software.

In one embodiment, the test includes five parts: (1) evaluate ILECprocedures used to ensure the accuracy and completeness of the DUF; (2)evaluate procedures used to ensure the reliability and timeliness of thedelivery of usage records to the CLECs 16 through the DUFs; (3) placecalls from one or more locations within the ILEC calling region, logthese calls, and compare information from the call logs to recordsactually received in the DUFs; (4) count the number of billable recordson delivered DUF cartridge tapes to ensure that no empty tapes weresent; and (5) the observe CLEC requests to retransmit DUFs.

Both procedural and transaction-based evaluation methods may be used.The first two parts listed above constitute procedural evaluations. Forthese evaluations, arrangements are made for ILEC SMEs to “walk through”ILEC procedures with the testing entity, according to a structuredchecklist. A walk-through summary may be provided to ILEC 14 and theregulatory entity. Sources of data for the procedural sub-tests includeILEC walk-through participants and associated documentation, incombination with any other suitable sources.

Parts three, four and five listed above are transaction-basedevaluations that focus on appropriate customer situations through theuse of test scenarios. In one embodiment, the most common test scenarioinvolves the migration of an ILEC retail customer to one of the testCLECs. To ensure that the test calling activities include migratingcustomers, the calling activities are preferably coordinated with thePOP GUI Interface Functional Test described above. In that case, ordersthat are placed during the POP GUI Functional Test should preferably beplaced shortly before the test calling period of this test so that theorders can complete during the test calling period. The sources of datafor the transaction-based tests may include the test calls, cartridgetapes containing DUFs that ILEC 14 delivers to the testing entity, andany electronic or other written descriptions of interactions between theILEC 14 and a CLEC 16 regarding retransmission of non-current DUFs.

The first transaction-based test (part three of the five-part approachdescribed above) involves data generation. In a particular embodiment,the testing entity uses specifically designed call matrices referred toas “test activity tools.” These tools provide instructions for placingcalls to specific numbers in specific ways. As an example, a certaintest activity tool may provide an electronic or other spreadsheet (e.g.,MICROSOFT ACCESS database) containing the specific phone numbers thatare to be called and any instructions designed to ensure a variety ofcall types and call lengths. The testing entity may record actual callinformation in the spreadsheet and communicate the spreadsheet to acentral database (e.g., every night following test calling). Forexample, a tester may place a number of calls according to a test scriptreflected in a spreadsheet, record associated call information in thespreadsheet, and forward the spreadsheet to a testing manager forfurther review or to the central database. The testing entity preferablylogs all calls attempted, whether or not the calls are completed.

To generate test calls of sufficient variety, the testing entity willpreferably dispatch its testers to a number of locations in the ILECcalling region. In one embodiment, the following statistical approach isused. A large number of calls are made for customers belonging to sixCOs. For purposes of organization, each CO is examined separately. Callsare made in three categories: (1) “Local” calls (made to destinationswithin the local calling area, charged using standard measured serviceor monthly flat fee); (2) “Toll” calls (made to destinations outside ofthe local calling region but still in the same Local Access andTransport Area (LATA), carrying an additional charge); and (3) “Other”calls (such as operator assisted calls, directory assisted calls,special service calls, and calls carried by IXCs). For each of the sixCOs, a sample of thirty calls is selected from the spreadsheet for eachof the three categories, totaling ninety calls per CO or five-hundredforty calls overall. The calls selected preferably vary widely in typeand represent most call types present in the retail call population. Thecustomer telephone numbers used to place the calls may belong to ILEC 14or to a test CLEC as appropriate. Testers within or outside the ILECcalling region may additionally place third party billing and collectcalls from non-test telephones to test telephones. Although particularnumbers of COs, calls, and categories are described, any suitable numberof COs, calls, and categories may be used according to particular needs.

In one embodiment, the testing entity compiles into a database all theusage records it receives using DUFs. Each call is examined to determinewhether the call should appear in the DUF. The database is also examinedto determine whether the DUF includes records for calls that should notappear in the DUF. For the calls that should have appeared, the testingentity examines the database to locate valid records meeting thespecifications of the calls as they were recorded in the call logs. ADUF file may be considered accurate upon verification that the values ofspecific fields in each record type in the DUF that is generated fromtest calls match expected results. Specific fields may include, forexample create date, time, record category, record group, record type,billed number, terminating number, and one or more indicatory values.Determining accuracy may also involve verifying that the header andtrailer records in the DUF accurately record the number of usage filescontained the file transmission and the individual DUF records. If aunique record cannot be identified as a match to the call log, therecord is designated as missing. A DUF may be considered complete whenall the billable incoming and outgoing test calls made by testers arecaptured on the DUF. Expected results may be developed for each testscript, against which DUFs may be compared in determining accuracy.

Typically, testers record information concerning the test calls (e.g.,originating number, terminating number, duration, etc.) manually, onpaper or perhaps using a personal computer or other device. Thismanually entered information, however, is typically not formatted thesame as bills that test CLEC receives as a result of the calls, makingcomparison more difficult, less efficient, and less reliable. To reducesuch disadvantages, the testing entity may establish a front-endprocessor supporting software designed to automatically generate testcall information in response to the test call being placed and thenformat the test call information such that it matches or at least moreclosely resembles the bills received from ILEC 14. This may allow manualcomparison to be performed more efficiently and reliably. Morepreferably, this may allow the comparison to be performed substantiallyautomatically, further increasing efficiency and reliability.

In one embodiment, the information collected in connection with testcalls may be parsed for use in validating bills during the BillingFunctional Bill Cycle Test described below. Each ILEC 14 may bill usagein a different manner, according to the ILEC's particular ratestructure. As just an example, a first ILEC 14 in a first jurisdictionmay assign seven billable elements to a toll call, but a second ILEC 14in a second jurisdiction may assign five billable elements to the sametoll call (one having the same pertinent characteristics). As a resultof such differences, the testing entity must organize information itcollects into seven fields in evaluating the first ILEC 14, but mustorganize information it collects into only five fields in evaluating thesecond ILEC 14.

To improve testing efficiency and reliability where the testing entitymay be evaluating multiple ILECs 14 in multiple jurisdictions, the testcall information is preferably parsed into items that collectively formthe billable elements for all the ILECs 14 in a group, which may includeall ILECs 14. The number of items is preferably greater than or equal tothe largest number of billable elements the testing entity might expectto encounter in evaluating any ILEC 14 within the group. For example,the testing entity might be able to parse the test call information intonine items available for use in generating ILEC billable elements. Usingthe example above, these nine items might be used to generate the sevenbillable elements for the first ILEC 14 by collapsing the first threeitems into the first billable element under the first ILEC's billingstructure. Similarly, these nine items might also be used to generatethe five billable elements for the second ILEC 14, by collapsing thefirst three items into the first billable element under the secondILEC's billing structure, and collapsing the last three items into thefifth billable element under the second ILEC's billing structure. Itemsinto which the test call information is parsed may be selected in anysuitable manner using domain experience or otherwise. As a result ofsuch parsing, the testing entity may more easily replicate this testwith respect to multiple ILECs 14.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures

Process Areas Sub-Process Areas Measures Criteria DUF Balancing andCompleteness of balancing 1-8  reconciliation and reconciliationprocedures of usage feed Route usage Controllability of usage 1-4, 9-14Transmit DUF Send direct connect Completeness, consistency 17-30  andtimeliness of process Send cartridge tape Completeness, consistency17-21, and timeliness of process 23-24, 28-30  Maintain usage Createusage backup Reliability of repeatable 15-16  history process Requestbackup data Availability of data 35-37  Status Tracking and Track validusage Completeness and accuracy of 31-33  Reporting data Timeliness ofDUF Account for no usage Completeness of data 34

Test results for evaluation criteria may be categorized according to thefive-part testing structure described above. Evaluation criteria forpart one may include, without limitation:

Procedural Consistency and Integrity: (1) scope and objectives of theprocess are clearly defined; (2) responsibilities for carrying outprocess are clearly assigned; (3) a complete (i.e. beginning-to-end)description of process is defined; and (4) the process is documented.

Performance Measurement and Reporting: (5) process performance measuresare defined and measured; and (6) the responsibilities for trackingperformance are assigned.

Process Elements: (7) control points enable identification ofout-of-balance conditions; (8) procedures exists for correcting andinvestigating any out-of-balance conditions; (9) the ILEC 14 tracks CLECusage from the ILEC's originating switch through message processing andonto the DUF; (10) the procedures for DUF creation include analysis forusage gaps and duplicates; (11) the ILEC 14 interfaces with acentralized message distribution system; (12) an error and exceptionprocess exists, for handling switch data without a valid guide rule;(13) the format of the DUF meets EMI industry guidelines; (14) the guidefile is updated frequently; (15) backup files are stored securely forthe number of days specified in regulatory or other applicablerequirements; and (16) disaster recovery procedures exist.

Evaluation criteria for part two may include, without limitation:

Methodology: (17) ILEC 14 has a well-documented interface developmentmethodology that addresses the design, testing, and implementation ofusage data transmission, and (18) the interface development methodologydefines how quality is to be assured.

Interface Specifications: (19) interface specifications define security(security measures are built into transport mechanism); (20) theinterface specifications define applicable business rules; (21) theinterface specifications define data formats and definitions (e.g.,variable definition and context); (22) interface specifications definerelevant transmission protocols (e.g., hardware, software, or networkrequirements); (23) the responsibilities and procedures for developing,updating, and distributing interface specification documentation areclearly defined; and (24) procedures for the updating of interfacespecifications are integrated with formal change management proceduresinvolving customers.

Interface Testing: (25) functioning test environments are available toCLECs 16 for the billing usage interface; (26) on-call technical supportis provided for the production interfaces; (27) on-call support isprovided to CLECs 16 for interface testing; and (28) CLECs 16 areprovided with documented specifications for active test environments.

Interface Support: (29) production performance is monitored; and (30)the procedures for addressing errors and exceptions are defined.

Evaluation criteria for part three may include, without limitation: (31)records for calls made from retail, resale, and UNE customer telephonesappear on the DUF when appropriate and the data appearing in the DUF iscomplete; (32) data in the DUF is accurate; and (33) call records appearon the DUF in a timely manner. In one embodiment, the test results forDUF accuracy may be organized by category and by calling location. DUFtimeliness may be measured, for example, according to the number ofbusiness days between the day a call was made and the day the callrecord appeared on the DUF, excluding the day the call was made and thetime it took the DUF to reach the test CLEC.

Evaluation criteria for part four may include, without limitation: (34)whether all DUF cartridges sent to the testing entity contain at leastone billable record.

Evaluation criteria for part five may include, without limitation: (35)ILEC 14 accepts requests from CLECs 16 to resend historical DUF files;(36) if the requested DUF files were originally sent no more than aspecified number (e.g., forty-five) of days before the CLEC request,then ILEC 14 fills the request; and (37) if requested DUF files wereoriginally sent more than a specified number (e.g., forty-five) of daysprior to the CLEC request, then the ILEC 14 notifies CLEC 16 that ILEC14 is not obligated to or cannot fill the request.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

F. Billing Functional Bill Cycle Test

This test provides an operational and systems analysis of the ILEC'sability to bill usage, monthly recurring, and non-recurring charges onthe appropriate type of bill in an accurate and timely manner. This testexamines the contents of carrier bills ILEC 14 delivers to test CLECs,the ILEC procedures for cycle balancing and bill delivery, and theILEC's ability to manage historical billing data (e.g., archives andresends). As described above, at least one reseller test CLEC and atleast one unbundler test CLEC are preferably established, although oneor more test CLECs may be organized in any suitable manner and may bewholly or partially integrated with pseudo-CLEC 18.

In general, ILEC 14 generates bills for reseller CLECs 16 and unbundlerCLECs 16 that purchase products and services from ILEC 14. Such carrierbills are the primary revenue collection mechanism for the ILEC'swholesale services. ILEC 14 generates and distributes many types ofbills over the course of a monthly billing period, each covering anassociated set of products and services. ILEC 14 typically generatesbills using two billing systems, one system for reseller CLECs 16 andone system for unbundler CLECs 16. In general, the ILEC's bills aredesigned to provide information to CLECs 16 about the products andservices purchased during the prior month. The bills are not designed tobe passed along “as is” to the customers of CLECs 16. CLECs 16 areresponsible for billing their customers directly using a CLEC-maintainedbilling system.

Reseller CLECs 16 may be served by the same system used to service theILEC's retail customers, since the retail and resale billing processesmay typically be similar. While retail customers each receive a singlebill listing all services, CLECs 16 receive aggregated bills for alltheir customers in the particular calling area served by ILEC 14.

The resale and retail billing processes are both driven by the billcycle, which is a code assigned to customers according to theiroriginating CO. As a result, all the ILEC's resale and retail customersassociated with a particular CO are billed on the same date, known asthe bill cycle date. Each reseller CLEC 16 has an associated resaleidentifier. Charges associated with the same resale identifier areaggregated in a single CLEC bill for the bill cycle. Once billingbegins, ILEC retail customers may be served using an ILEC retail billingprocess, while the reseller CLECs 16 may be served using an alternativeILEC reseller billing process. Across the ILEC calling region, multiplebill cycle dates may be used and multiple COs might share a single billcycle date. When a reseller CLEC 16 operates in multiple COs, billingmay take place over several bill cycles, depending on the cycle datesassigned to the COs in which the reseller CLEC 16 operates.

In addition to billing the reseller CLECs 16 for charges incurred bytheir customers, the reseller system also generates bills based on theproducts and services the reseller CLECs 16 order for themselves. Forexample, a CLEC 16 will typically receive an administrative bill shortlyafter the first of the month containing charges attributable to CLEC 16rather than to customers of CLEC 16. For example, DUF delivery chargesare among the charges found on this type of bill.

Unbundler CLECs 16 are primarily served by the ILEC's alternativebilling system. Unbundler CLECs 16 may receive multiple bills from ILEC14 depending on the products ordered. Similar to the reseller system,the unbundler system separates products into specific bills—in this casegenerated on a per LATA basis.

In one embodiment, this test is organized into four parts, including butnot limited to: (1) evaluating carrier bill content, (2) evaluating billdelivery timeliness, (3) evaluating bill cycle balancing procedures, and(4) evaluating the procedures for managing historical billing data(including resending prior bills to CLECs 16 upon request). Once thetest bed is established, test CLECs 18 begin to receive bills from ILEC14. These bills are the basis for evaluation for parts one and twoabove, with charges being examined for both resale and UNE billing.Structured interviews are the basis for evaluation for parts three andfour above. Summaries of the interviews may be provided for comment toILEC 14 and the regulatory entity.

The analysis of carrier bill content (part one of the test) uses adata-driven approach to evaluate the completeness and accuracy ofcharges that should appear on the bill based on staged input data. Thisevaluation is dependent on the successful execution of correspondingordering and provisioning scenarios during POP Domain testing. Stagedinput data may include data in the original test bed, modifications tothe test bed associated with certain test scenarios, and usageinformation generated in connection with the Billing Functional UsageTest described above.

In one embodiment, to evaluate carrier bills, the testing entity firstdevelops a thorough understanding of bill structure and content. Thetesting entity preferably reviews appropriate portions of an ILEChandbook relating to bill structure, content, and elements for each ofthe relevant bill types. In addition, the testing entity may conductwork sessions with one or more ILEC SMEs to review relevant bill typesin more detail.

The testing entity constructs detailed evaluation materials, includingsuitable test cases, worksheets, and procedures, for evaluating each ofthe bill types involved in the test. In doing so, the testing entity maydevelop a framework to accommodate the wide variety of test casessuitable for use in evaluating carrier bills. These test cases may bebased on any of the scenarios used in connection with POP Domain testingor any other suitable scenarios. CLEC-level (aggregate) billing testscases are designed to examine the wide variety of billing situationsreflected on the summary and administrative bills that CLECs 16 receive.The remaining billing test cases are designed to examine customer-levelbilling situations. Certain test cases may focus on customers for whichno changes were made during the billing period, while others may focuson customers for which changes were made.

The testing entity defines expected results for each test case and testcycle. This may include selecting scenarios in connection with POPDomain testing and performing data collection activities during POPDomain activities for later use in analyzing carrier bill content. Datacollection may include collecting ordering data, completionnotifications, CSRs, DUFs containing usage data generated during theexecution of the Billing Functional Usage Test, or any other suitableinformation. The testing entity analyzes the collected data to formulateexpected results against which carrier bills are evaluated.

For example, after a change occurs during POP Domain testing, ILEC 14may generate a completion notification and communicate it to test CLEC18. In general, completion notifications describe changes to customeraccounts and charges ILEC 14 generates when making the changes. Theseone-time charges may also be referred to as non-recurring billinginformation. Billing test cases often focus on the bills that ILEC 14generates following its generation of completion notifications to ensurethat any resulting charges are applied and prorated correctly. Thus,after a completion notification is received, the testing entity maycreate a test activity tool (described above) for the associatedcustomer account. The testing entity may also obtain the CSR for thecustomer account to formulate expected results for the carrier bill. TheCSR contains recurring billing information. The testing entity mayfurther examine DUFs, consult ILEC documentation, and review publiclyavailable tariffs to formulate the expected results.

The expected results may be expressed in the form of mock bills or inanother suitable manner, according to particular needs. In oneembodiment, the creation of a mock bill helps to substantially reduce oreliminate any bias that might result from attempts to reconstruct, withthe benefit of hindsight and perhaps giving ILEC 14 the benefit of anydoubt, the manner in which ILEC 14 generated the bill. The testingentity may extract data from the fields of orders, completionnotifications, CSRs, or any other electronically available sources andautomatically populate one or more appropriate fields of the mock billwith the extracted information.

ILEC 14 generates carrier bills in either paper or electronic form andthen communicates the bills to test CLECs 18. After a bill is received,the testing entity compares the bill content with the expected resultsaccording to suitable evaluation criteria and notes any discrepancies.In one embodiment, the fields of an electronic bill may be comparedautomatically with the corresponding fields of an electronic mock billto improved reliability and efficiency. Where manual comparisons areused, standardized worksheets may be created for each bill type toprovide the tester with the objectives of the test or a portion thereof,define the data to be compared for the test or test portion, providedetailed procedures the tester is to follow in making the comparisonsfor the test or test portion, and other detailed information. Use ofsuch worksheets preferably improves consistency for a particular testand across all testers and therefore the reliability of the testresults.

The testing entity may examine CLEC-level (aggregate) billinginformation, as well as customer-level billing information. As anexample, aggregated billing information may include totals for aparticular calling area. The testing entity may count the number of testcalls placed in the particular area during a particular time period andthen compare the counts appearing on the bills to the number of testcalls actually made. As another example, the testing entity might countthe number of cartridge tapes a test CLEC 18 receives and compare thisto the number of cartridge tape delivery charges appearing on the CLECadministrative bill. For customer-level test cases, the testing entityexamines all products and services associated with the customer accountto verify that products and services the customer ordered appear on thebill and were billed accurately. The testing entity might furtherexamine the bill format to determine whether all of the required chargetypes (e.g., prorates, recurred charges, usage charges, etc.) appear onthe bill.

The relationships between various components that may be used for partone of the test are illustrated in FIG. 16. Although FIG. 16 is providedas an example, the present invention contemplates one or more of thesecomponents being absent or used in a different manner according toparticular needs.

In a particular embodiment, a work plan suitable for this test mightinclude the following sequence of activities, although any suitableactivities and sequence may be used according to particular needs: (1)meet entrance criteria, (2) document the test schedule andparticipation, (3) meet with ILEC SMEs to review sample bills, (4)determine appropriate billing scenarios and quantity, (5) determine CSRinformation needed for completion, (6) obtain tariff, EMI, andinformational material, (7) collect telephone and circuit ID informationfor test cases, (8) review billing information from the ILEC 14 andperform walkthrough of bills, (9) obtain telephone and circuit numbersfor usage test, (10) develop detailed test cases, (11) create backupdetail for test cases (TNs, products, usage types), (12) identify anymodifications to evaluation criteria if necessary, (13) identify keyfields required to validate evaluation criteria, (14) definerequirements for usage totaling, (15) develop test package, (16) submittest package for peer review, (17) define records for different billtypes to be tested, (18) obtain reliable CSR information for billingorders, (19) collect bills for first and second consecutive cycles foreach bill type, (20) validate bills for first and second cycles for eachbill type, (21) identify discrepancies and exceptions from validatedtest cases, (22) create and update issues log, (23) develop loggingprocedures for bills received and log all bills, (24) log all workpapers and documentation, (25) compile final results, (26) write finalreport, and (27) submit final report for peer review as part of exitreview process.

Analysis of bill delivery timeliness (part two of the test) involvesexamining procedures the ILEC 14 uses to generate carrier bills and sendthe bills to CLECs 16. The testing entity may also rely upon interviewswith ILEC SMEs and review of associated documentation. In oneembodiment, the bill timeliness analysis has two primary components. Thefirst component is a statistical analysis of the bill dates incomparison to the dates the bills are received. As bills are received,dates of receipt and the bill dates are recorded and the numbers ofelapsed business days calculated. This data is statistically analyzed todetermine timeliness. The second component involves comparing datacollected from the interviews and documentation with the appropriateevaluation criteria.

Analysis of cycle balancing procedures (part three of the test) andanalysis of procedures for managing historical data (part four of thetest) involve interviewing ILEC SMEs and examining associateddocumentation to determine whether adequate controls exist, based onappropriate evaluation criteria. The latter analysis may also include anevaluation of events associated with actual requests for historicalbilling data. In this case, for example, the testing entity (acting aspseudo-CLEC 18) may request that ILEC 14 resend historical billing datain the form of prior carrier bills or otherwise.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures

Process Areas Sub Process Areas Measures Criteria Maintain bill balanceCarry balance forward Accuracy of bill balance 82-93, 101-106, 109-110,118-124, 129-134  Verify billing accounts Verify billing accountsCompleteness and accuracy of 1-3, 12- extraction 17, 24- 29, 33- 35, 58-63, 69- 71, 128 Billing accuracy Verify normal recurring Completenessand accuracy of 18-23, charges data 64-67, 72-75, 107 Verify one-timecharges Completeness and accuracy of 4, 7, 21- data 23, 36- 39, 68- 71,76- 81, 108, 125, 127 Verify prorated recurring Completeness andaccuracy of 5-6, 8- charges data 11, 22- 23, 40- 57, 69- 71, 125 VerifyUsage Charges Completeness and accuracy of 95-100, data 112-117, 126Verify discounts Completeness and accuracy of 4-11, 18- data 21, 36- 57,64-75 Verify adjustments (debits Completeness and accuracy of 30-32, andcredits) data 135 Verify late charges Completeness and accuracy of 94,111 data Balance cycle Define cycle balancing and Completeness and 144-146, reconciliation procedures effectiveness of balancing and150-156 reconciliation procedures Produce Control Reports Completenessand accuracy in 147-149 generation of control elements Release cycleCompliance with balancing 152-153 and reconciliation procedures Deliverbill Deliver Bill Media Timeliness and controllability 136-143 of mediadelivery Maintain bill history Maintain billing information Timelinessand controllability 157-160 of billing information Access billinginformation Accessibility and availability 161-162 of billinginformation Request resend Timeliness and Accuracy of 163-164 thedelivery

Evaluation criteria for bill content may include one or more of thefollowing, without limitation:

Analysis of CABS Bill Content

Criteria Description Other Charges and Credits/Service Order Level 1Service Order Completion Date = Expected Completion Date 2 PON = TestCase PON 3 Expected TNs = Actual TNs 4 Beginning and thru dates forservices correspond to the expected result 5 USOC/Actual services listedmatch expected 6 New services/disconnect services appear as fractionalcharges 7 One time charges are labeled 8 Zone matches expected result 9Amount matches expected result 10 Quantity matches expected result 11Rate matched expected rate Customer Service Record (CSR)/TN Level 12Customer service address = test case address 13 PIC matches expectedresult 14 LPIC matches expected result 15 TNs listed for the CSR matchthe expected TNs in the test case 16 Activity dates for TNs correspondto the expected activity dates. 17 All expected USOC/services per TN arelisted 18 The quantities per TN/USOC = expected result 19 The amount =expected amount for monthly recurring charge 20 Other Features matchexpected Other 21 Service Order ID Matches Completion 22 All expectedUSOCs appear 23 No unexpected USOCs appear

Analysis of CRIS Resale Bill Content

Criteria Description Bill Content Service Order Charges and CreditsBTN/TN Information: 24 BTN/TN ID = expected BTN/TN ID 25 BTN/TN =expected BTN/TN Completion Date, Order ID, PON: 26 Begin Order ID =expected Begin Order ID 27 Completion Date = expected Completion Date 28Order ID = expected Order ID 29 PON = expected PON Detail of Adjustmentswith Charges: 30 Adjustment Info ID = expected Adjustment Info ID 31Adjustment Phrase = expected Adjustment Phrase 32 Adjustment Charge =expected Adjustment Charge USOC Information: USOC From And Thru Date: 33USOC Information ID = expected USOC Information ID 34 From date =expected From date 35 Thru date = expected thru date USOC Name,Quantity, and Charge Amount: 36 USOC Information ID = expected USOCInformation ID 37 USOC Name = expected USOC Name 38 Quantity = expectedQuantity 39 Amount = expected Amount Bill Content Local Calls, MassAnnouncements, and Directory Assistance: 40 Non-Itemized Usage ID =expected Non-Itemized Usage ID 41 Originating # = expected Originating #42 Quantity = expected Quantity 43 Rate = expected Rate 44 Total Amount= expected Total Amount 45 Initial/Additional Ind. 46 Call Region/CallType = expected Call Region/Call Type Itemized Convenience Calls 47Itemized Usage ID = expected Itemized Usage ID 48 Telephone # = expectedTelephone # Bill Content Service Order Charges and Credits 49 Date =expected Date 50 Call From Location = expected Call From Location 51From Number = expected From Number 52 Call To Location/Type of Call =expected Call To Location/Type of Call 53 Terminating # = expectedTermination # 54 Time = expected Time 55 AM/PM = expected AM/PM 56Duration Min/Sec = expected Duration Min/Sec 57 Amount = expected AmountBill Content TN Level Checks for CSR: BTN: 58 CSR ID = expected CSR ID59 BTN = expected BTN USOC Name, PIC, LPIC: 60 USOC Info ID = expectedUSOC Info ID 61 USOC Name = expected USOC Name 62 PIC = expected PIC 63LPIC - expected LPIC USOC Quantity and Monthly Rate: 64 CSR Info ID =expected CSR Info ID 65 Quantity = expected Quantity 66 Monthly Rate =expected Monthly Rate 67 Charged Amount = expected Charged Amount USOCGeneral 68 USOC General Other Charges and Credits/Service OrderLevel/Order Level 69 PON = Expected PON 70 Order From and Through Dates= Expected From and Through Dates 71 Actual Circuit ID associated withan order Circuit ID Level 72 Actual services listed match expectedservices 73 Per month charges for the specified service match theexpected monthly charge 74 Amounts for the specified service match theexpected amount 75 Order from and through dates match to expected datesfor each service.

Analysis of CRIS Administrative Bill Content

Criteria Description Other Charges and Credits: 76 Records Processedcounts listed match expected results 77 Dates for Records Processedlisted match expected results 78 Local Usage Transmission counts matchexpected results 79 Dates for Local Usage Transmission match expectedresults 80 Tape Cartridge counts match expected results 81 Dates forTape Cartridges match expected results

Analysis of Format, Bill Calculation and Cross Checks for CRISAdministrative, CRIS Abbreviated, CRIS Loop, CRIS Loop Summary, CABSY40, and CRIS Summary Listing Bills

Criteria Description Bill Format Sections Validation 82 Bill FormatSections 83 Page Headers 84 Remittance Section 85 Summary of Accounts 86Summary of Bill total Amount 87 Customer Service Section 88 Summary ofILEC Charges 89 Monthly Service-Detail 90 Itemization of Charges 91Other Charges and Credits 92 Address Page Mailing Page 93 Total ofBalance Due 94 Total of Late Payment Charges 95 Detail of Usage Charges96 Detail Summary of Usage Charge 97 Summary of Usage Charges 98 Detailof Usage Statistics 99 Detail Summary of Usage Charge for All End Office100 Summary of All Usage Charges 101 Detail of Tax 102 Detail ofSurcharge 103 Customer Service Section 104 Summary Bill Total Amount 105Summary of Account 106 Summary of ILEC Charges 107 MonthlyService-Detail 108 Other Charges and Credits 109 Itemization of Charges110 Detail of Balance Due 111 Detail of Late Payment 112 Detail of UsageCharges 113 Detail Summary of Usage Charge 114 Summary of Usage Charges115 Detail of Usage Statistics 116 Detail Summary of Usage Charge forAll End Office 117 Summary of All Usage Charges 118 Detail of Tax 119Detail of Surcharge 120 Customer Service Records Bill Cross Check 121Remittance Page and Summary of Accounts 122 Summary of Account 123Summary of Charges

Analysis of Format, Bill Calculation, and Cross Checks for CRIS ResaleBill on BOS BDT

Criteria Description Bill Record ID Validation: 124 Control Records 125OC&C Records 126 Usage Records 127 Surcharge Records 128 CSR RecordsElements for Verification in Record IDs 129 Elements for Verification inRecord IDs 130 Record ID: 10050501 131 Record ID: 40100500 BillCalculations 132 Local Billed Amount = Monthly Charges Total 133 OC&CAmount Local = Total Other Charges and Credits 134 Local Subtotal =Local Total 135 Adjustment Amount = Total Credit Adjustment

Evaluation criteria for bill delivery timeliness may include one or moreof the following, in any suitable combination and without limitation:

Procedural Consistency and Integrity: (136) the bill deliveryresponsibilities are clearly defined; (137) the scope and objectives forbill delivery are clearly defined, documented, and communicated toensure accurate and timely billing; (138) the process includesprocedures to ensure creation of customer bills on the appropriatemedium; and (139) the process includes procedures to ensure that billingmedia are transmitted or shipped per established schedules to correctlocations.

Performance Measurement and Reporting: (140) suitable processperformance metrics are defined and measured; (141) responsibilities fortracking performance are assigned; (142) process improvement proceduresare defined and responsibilities assigned; and (143) bills are timely,as defined in industry guidelines or otherwise (bill timeliness may beexpressed according to the cumulative percentage of bills arrivingwithin a specified number of business days, for example, thirteenpercent in three business days, forty-two percent in four business days,and so on).

Considerations relevant to particular evaluation criteria may include,without limitation (consideration for a criterion being listed after thenumber of the criterion): (136) organization charts, job descriptions,responsibility charters, process flows and procedures, inputs andoutputs; (137) scope includes timely creation and delivery of customerbill on the correct medium, objectives are clearly defined, documented,and communicated to CLECs 16, scope of support defined, access toservices is defined and appropriate, customer responsibilities andcustomer-provided data requirements defined; (138) maintenance ofcustomer media selection, verification of production quality checks;(139) scheduling and execution, verification of correct receipt, eventlogging and follow-up, standard intervals, sign-offs, escalation; (140)existence of measures and measurement processes; (141) responsibilitiesassigned, management reviews, management intervention; and (142)historical performance improvement activities, responsibilitiesassigned, management review.

Evaluation criteria for bill cycle balancing procedures may include oneor more of the following, in any suitable combination and withoutlimitation:

Procedural Consistency and Integrity: (144) these responsibilities areclearly defined; and (145) scope and objectives of bill cycle balancingare clearly defined, documented, and communicated to ensure accurate andtimely billing.

Balance Bill Cycle Process: (146) an internal change managementprocedure is in place to document process changes; (147) processincludes procedures to ensure all customer data (e.g., service orders,address changes, usage) has been properly introduced and applied; (148)the process includes procedures to ensure all payments and adjustmentshave been properly introduced and applied; (149) process includesprocedures to ensure customer data has been rolled forward from previousbill cycle; (150) the process includes reasonability checks to catcherrors not susceptible to predetermined balancing procedures; (151)process provides for visual check of printed bills; (152) procedures andchecks are in place to assure all stages within the billing process arevalid; and (153) the process includes procedures for requesting,tracking, and escalating remedial actions.

Performance Measurement and Reporting: (154) process performance metricshave been defined and measured; (155) responsibilities for trackingperformance are assigned; and (156) process improvement procedures aredefined and responsibilities assigned.

Considerations relevant to particular evaluation criteria may include,without limitation (consideration for a criterion being listed after thenumber of the criterion): (144) organization charts, job descriptions,responsibility charters, process flows and procedures, inputs andoutputs; (145) scope includes creation of accurate customer bill,objectives are clearly defined, documented, and communicated tocustomers, the scope of support is defined, access to services isdefined and appropriate, customer responsibilities and customer provideddata requirements are defined; (146) test beds and test data, controlaccounts, control totals, user sign-off; (147) control reports, errorlogs, error recycling, feed back messages, “go/no go” decisions; (148)control reports, error logs, error recycling, feed back messages, “go/nogo” decisions; (149) control reports, error logs, error recycling, feedback messages, “go/no go” decisions; (150) cycle to cycle comparisons ondollars or usage, verification of key accounts; (151) visual checks forformat, print quality; (153) event logging and follow-up, standardintervals, sign-offs, escalation; (154) existence of measures andassociated measurement processes; (155) responsibilities assigned,management reviews and intervention; and (156) historical performanceimprovement activities, responsibility assigned, management reviews.

Evaluation criteria procedures for managing historical billing mayinclude one or more of the following, in any suitable combination andwithout limitation:

Procedural Consistency and Integrity: (157) bill history maintenance andbill resend responsibilities and activities are clearly defined,documented, and communicated to ensure availability and timely deliveryof prior period billing information to customer; (158) a completedescription of the process is defined and documented; (159) processincludes procedures to ensure bill history retention requirements areoperationally satisfied; and (160) process includes procedures todefine, initiate, track, and manage retrieval and transmission ofcustomer requested billing information;

Request Resend Process: (161) customers are provided with instruction onhow to request, track, and expedite billing resends; (162) the processincludes procedures to log requests and communicate request status tocustomers; (163) ILEC 14 accepts requests from CLECs 16 to resendhistorical billing files; and (164) ILEC 14 resends historical billingfiles in a reasonable period of time.

Considerations relevant to particular evaluation criteria may include,without limitation: (157) organization charts, job descriptions,responsibility charters, process flow and procedures, inputs andoutputs; (158) scope includes timely re-creation and re-issuance ofprevious period customer bill, objectives are defined, documented, andcommunicated to customers; (159) retention rules, archiving process,off-site storage, disaster recovery; (160) data retrieval, specialprogramming requirements, medium selection and creation, transmission ordelivery, event logging and follow-up, standard intervals, sign-off,escalation; (161) documentation, telephone support; and (162) scope ofsupport is defined, access to services is defined and appropriate,customer responsibilities and customer provided data requirements aredefined.

Due to the nature of this test, instead of generating particularexceptions for each evaluation criteria mismatch, discrepancies for thevarious test cases may be grouped into categories of exceptions. In oneembodiment, the exception categories may include, without limitation:(1) system-wide billing issues, (2) validation billing issues, and (3)specific content issues. System-wide issues are repeatable and occurconsistently throughout the test cases such that they are likely to beglobal in nature. Validation issues affect the ability of CLECs 16 tovalidate billing data, including but not limited to carrier billsreceived from ILEC 14. These issues may include bill presentation anddocumentation issues that hinder the ability of CLECs 16 to validate thecharges on the bills. Specific content issues occur in specific bills,with only one test case for example, and are not identified as beingsystem-wide in nature. While this exception may identify only oneoccurrence, the issue may be present system-wide and should preferablybe investigated under that assumption.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

RMI Domain

The general purpose of testing in the RMI Domain is to evaluate thesystems, processes, and other operational elements associated with theILEC's establishment and maintenance of business relationships with itswholesale customers—CLECs 16. RMI Domain testing is designed to evaluatethe ability of the ILEC 14 to provide ongoing operational support toCLECs 16 in a manner that is both adequate to CLEC business needs andcomparable to that provided to the ILEC's retail operations. The reportgenerated by the testing entity should preferably allow the regulatoryentity to assess the net impact of RMI Domain issues that it identifieson the ability of CLECs 16 to operate in a competitive environment forlocal telecommunications services in the particular jurisdiction ofinterest.

In one embodiment, the RMI Domain may be broken down into the followingkey test target areas: (1) change management; (2) interface development;(3) account establishment and management; (4) network design,collocation, and interconnection planning; (5) system administrationhelp desk; (6) CLEC training; and (7) forecasting. Each primary testtarget area may be further broken down into increasingly discreteprocess and sub-process areas that identify the particular areas to betested and the types of evaluation measures that apply within each area.According to the present invention, tests have been developed toevaluate each test target area based on the scope of testing to beperformed in each area. Particular example process and sub-process areasfor each test target area, with example associated evaluation measuresand evaluation criteria, are provided below.

There need not be a one-to-one correspondence between test target areasand specific tests. In one embodiment, RMI Domain tests include one ormore of the following, without limitation: (1) Change ManagementPractices Test; (2) Interface Development Test; (3) AccountEstablishment and Management Test; (4) Network Design, Collocation, andInterconnection Planning Test; (5) System Administration Help DeskFunctional Test; (6) System Administration Help Desk Performance Test;(7) System Administration Help Desk Validation Test; (8) CLEC TrainingTest; and (9) Forecasting Test. Example embodiments of these tests aredescribed in detail below.

A. RMI Change Management Practices Test

This test evaluates the ILEC's overall policies and practices formanaging change in the systems, processes, and any other operationalelements necessary for establishing and maintaining effectiverelationships with CLECs 16. The objectives of the test are to determinethe adequacy and completeness of ILEC procedures for developing,publicizing, conducting, and monitoring change management. Changemanagement processes provides a framework by which interested partiessuch as CLECs 16 can communicate desired changes to ILEC 14 and by whichILEC 14 can communicate subsequent changes to these interested parties.Typically, the process will govern all aspects of ILEC/CLECrelationships—all changes to documentation, interfaces, business rules,and other functions are subject to time frames, tracking, logging, andcoding procedures of the change management process.

In one embodiment, changes are organized by the following types, withoutlimitation: (1) emergency changes, reserved for modifications requiredimmediately to continue doing business; (2) changes that are specifiedby regulatory requirements or otherwise arise from regulatory activity;(3) changes that are specified by industry standards or otherwise arisefrom industry activity; (4) ILEC initiated changes, which may or may notaffect ongoing CLEC operations; and (5) CLEC requested changes. Theprocess is initiated through submission of a change request having anyof the types listed above. The submitting entity may provide a priorityfor the request in addition to specifying its type. ILEC 14 thendetermines the overall priority for the request. ILEC change managementdocumentation should specify required intervals for evaluating and, whenappropriate, implementing changes of each type. ILEC 14 should make anymodified documentation available for review for a suitable period priorto implementation of non-emergency changes.

Sources of data for the test may include structured interviews with ILECand industry SMEs conducted according to interview guides, suitable ILECand industry documentation relating to change management, any actualchange requests ILEC 14 makes available to the testing entity, the ILECchange management database, and any other information sources. Thetesting entity may evaluate ILEC compliance with required or targetednotification, documentation, and functionality roll-out intervals foreach type of change request. For example, an ILEC initiated change mayrequire notification of CLECs 16 and distribution of documentation toCLECs 16 specified numbers of days prior to implementation. Analysis ofactual change requests that ILEC 14 provides in response to a datarequest may include determining whether suitable change notificationsand documents were generated and communicated to interested parties.Instead or in addition, the testing entity (acting as pseudo-CLEC 18)may submit changes requests to ILEC 14 and then monitor thenotifications and documentation that ILEC 14 generates in response tothe requests.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures

Process Areas Sub-Process Areas Measures Criteria Change managementDeveloping change Completeness and consistency 1-8 proposals of changedevelopment process Evaluating change proposals Completeness andconsistency 1-2, 4, 7- of change evaluation process 8 Implementingchange Completeness and consistency 1-8 of change implementation processIntervals Reasonableness of change 3-8 interval Documentation Timelinessof documentation 3-4, 6 updates Tracking change Adequacy andcompleteness 1, 3, 5-6 proposals of change management tracking process

Evaluation criteria for this test may include one or more of thefollowing, without limitation: (1) change management processresponsibilities and activities are clearly defined; (2) the essentialelements of the change management process are in place and adequatelydocumented; (3) the change management process includes a framework toevaluate, categorize, and prioritize proposed changes; (4) the changemanagement process includes procedures for allowing input from allinterested parties; (5) change management process has clearly definedand reasonable intervals for considering and notifying interestedparties with respect to proposed changes; (6) documentation regardingproposed changes is distributed in a timely manner; (7) adequateprocedures and systems exist to track information such as descriptionsof proposed changes, important notification dates, and change status;and (8) criteria are defined for the prioritization systems and severitycoding.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

B. RMI Interface Development Test

This test is designed to evaluate key aspects of the ILEC's approach tothe development and maintenance of interfaces that enable ILEC-CLECrelationships. This may include evaluating the existence and operationof the ILEC's systems and processes for developing, publicizing,conducting, managing, and monitoring certain interface development andassociated support activities for CLECs 16.

As described more fully above, for example, CLECs 16 may access ILECsystems for ordering, pre-ordering, and other services using EDIinterface 30 or GUI interface 32. A CLEC 16 intending to interface withILEC 14 is typically instructed to initiate its efforts through an ILECaccount manager, who assigns one or more interface developmentspecialists to assist CLEC 16 in accessing and using one or moreappropriate interfaces. The work required to facilitate CLEC access toEDI transaction interface 30 in particular may be extensive. In general,ILEC 14 will be responsible for working with the CLEC 16 to establishEDI or other appropriate connectivity and for providing access tonon-production systems so that CLEC 16 may test its interfacecapabilities prior to live implementation (similar to the effortsdescribed above in connection with the POP EDI Interface CertificationTest). The work required to facilitate CLEC access to GUI interface 32may be less extensive, but will still generally require the ILEC 14 toprovide the CLEC 16 with training, documentation, necessary securityhardware, passwords, and the like.

The sources of data for this test may include interviews with ILEC SMEsaccording to one or more interview guides, review of relevant ILECdocumentation, and any other appropriate information sources. Testactivities may include, without limitation: (1) gather appropriateinformation; (2) review the interface development products to assesswhether their successful completion was performed as anticipated withrespect to timeliness, accuracy, or other criteria; (3) perform theinterviews and documentation reviews; (4) complete evaluation checklistsand interview summaries; and (5) develop and document findings inreport.

Several aspects of the test may warrant multiple iterations. Forexample, during the initial phase of testing, the testing entity mightidentify concerns about carrier-to-carrier testing procedures,availability of adequate test environments, or other issues. As aresult, retest activities may be warranted to validate proposed andimplemented corrective actions.

For example, the testing entity may review defined testing proceduresand conduct preliminary test activities to assess the existence andfunctionality of the ILEC's implemented and proposed test environments.Such activities may include, without limitation: (1) establishingsecurity and user authentication for carrier-to-carrier testing; (2)sending and receiving pre-validated EDI test transactions; (3)confirming test environment availability, capabilities, and capacity;(4) receiving test bed information (such as a listing of test accountsfor which pre-ordering transactions can be developed); (5) obtainingstandard sets of test cases and transactions that have beenpre-validated to work; (6) following the ILEC's established testingprotocols, such as working within standard schedules for CLEC access totesting environments and support; and (7) logging and reporting issuesencountered during testing.

As another example, the testing entity may assess the reasonableness ofa development process for joint carrier-to-carrier test planning. Thetesting entity may also verify that proposed and implemented testenvironments adequately resemble production environments, including butnot limited to assessing the procedure for conducting object librarycomparisons between test and production environments, confirmingpublication of ILEC internal regression testing results using apublished test bed, and verifying the existence of a published testaccount database and any associated modifications or additions. Thetesting entity might further assess the procedures for notifying CLECs16 of changes to test environments and test tools, including confirmingthat schedules for changes affecting the test environments and testtools were followed and confirming that changes made to testenvironments and test tools were distributed as specified. Anyappropriate retest activities may be conducted according to particularneeds.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures

Process Areas Sub-Process Areas Measures Criteria Interface developmentSoftware development Adequacy and completeness 2 methodology ofmethodology Interface development Adequacy and completeness 1-3 ofmethodology Provision of specifications Adequacy and completeness 4-7and related documentation of documentation distribution proceduresEnabling and testing Interface enabling and Adequacy and completeness 7,9, 11, interfaces testing methodology of carrier-to-carrier enabling 13and testing procedures Availability of test Availability and adequacy of9, 11, 13 environments and technical functioning test environments,support to CLECs testing protocols, production cutover protocols, andtechnical support for all supported interfaces Installing interfacesImplementation Compliance with planned 2-3 schedule of developmentMaintaining interfaces Release management Adequacy and completeness 2-4,13, of interface enhancement and 17-20 software release protocolsCapacity management Capacity management Adequacy and completeness 8, 10,12, of capacity management 21-23 practices for interfaces and gatewaysystems

Evaluation criteria for this test may include one or more of thefollowing, in any suitable combination and without limitation:

Methodology: (1) development responsibilities and activities clearlydefined; (2) ILEC 14 has a software/interface development methodologywhich addresses the definition, design, development, testing, andimplementation of requirements and specifications; and (3) themethodology defines how quality will be assured.

Interface Specifications: (4) responsibilities and procedures fordeveloping and updating interface specification documents are clearlydefined; (5) the interface specifications that define applicablebusiness rules, data formats and definitions, and transmission protocolsare made available to CLECs 16; (6) on-call customer support forinterface specifications is available to CLECs 16; and (7) proceduresfor updating specifications are integrated with formal change managementprocedures.

Carrier-to-carrier testing: (8) ILEC 14 has a methodology for planningand conducting carrier-to-carrier testing with CLECs 16 seeking tointerconnect, including process descriptions for establishing securityand user authentication, for establishing test accounts, and for sendingand receiving test transactions; (9) functioning test environments andappropriate descriptions are made available to CLECs 16 for allsupported interfaces; (10) test environments are stable and segregatedfrom ILEC production environments; (11) on-call support is available forinterface testing; (12) CLECs 16 are provided with documentedspecifications for test connectivity and for administration of tests;(13) active test environments are subject to version control, and CLECs16 are notified before version changes are made in test environments;(14) procedures are defined to log software “bugs,” errors, omissions inspecifications, and other issues discovered during carrier-to-carriertesting; (15) on-call support is available for ILEC productioninterfaces; and (16) regular communication forums (e.g., meetings,newsletters, workshops) are held for the benefit of CLEC interfacedevelopers.

Release Management: (17) ILEC 14 has software and interface developmentmethodology that defines the release management and control process;(18) business rules and software change logs exist, are updated, and areshared with CLECs 16 in a timely manner; (19) technical and businessprocesses for software testing, bug fixes, release notification, and thelike exist and are adhered to throughout CLEC interface development andpre-production testing; and (20) measures exist for contingency planningwithin release management.

Capacity Management: (21) there are defined business scenarios,conditions, or transactions volumes that will trigger the addition ofcapacity, load-balancing, or system tuning; (22) resources andprocedures are in place to adjust for changes in demand of services; and(23) contingency plans for production interfaces exist for mitigatingthe impact of unexpected changes in business and transaction volume.

Considerations relevant to particular evaluation criteria may include,without limitation (consideration for a criterion being listed after thenumber of the criterion): (1) organization charts, job descriptions, andresponsibility charts exist; (2) process is implemented and guidelinesare followed, process is documented, documentation is available,adequate, clear, and relevant, all results from pre-production testingare documented and available, all results from acceptance testing aredocumented and available; (3) quality control processes, quality testingand audits, acceptance testing is performed to demonstrate that thesoftware satisfies its requirements, defects and required changes areidentified and tracked during pre-production testing, methods andprocedures are defined to ensure that changes found during all phases oftesting are incorporated into all instances of software code; (4)framework and guidelines exist, documentation is complete and available,and changes are communicated both internally and to customers; (5)procedures are clearly defined, documentation is complete, transmissionspecifications are published, and project plans are available; (6)support process is documented, contact data is published, supportpersonnel are well trained and able to respond to information requests;(7) proposed changes are pro-actively made available, distribution isvia email or other rapid delivery medium, intervals are aligned withgenerally accepted industry standards; (8) methodology is documented,procedures are available, network connectivity assistance is available,information is readily available to CLECs 16; (9) test environments areavailable, guidelines are clearly communicated to CLECs 16, assistanceis available; (10) tools and documentation exist, project plan review;(11) procedures are followed, support contact information is provided,support personnel have the knowledge and the tools necessary to providerequired support, communication guidelines are followed; (12)documentation is made available, customer requirements (business rules,technology requirements) are a guide for software development; (13)notification process exists, sufficient time is allowed for CLECreaction to changes in test environments; (14) procedures exist,personnel are assigned to correct, carriers are notified; (15) supportis available, contact information is provided, procedures and supportdocumentation is available; (16) the process is clearly stated, meetingschedules are made available, ILEC 14 actively and regularly solicitsinput; (17) process is the same as the one described for evaluationcriteria (3), process is documented; (18) database exists for loggingall proposed activity, customer requests are answered and tracked, aprocess is in place for considering CLEC input, in addition toescalation procedures in cases where a resolution cannot be reached;(19) future releases are released on schedule basis, acceptance testingof all new releases allows adequate time for CLECs 16 to developchanges, test bed for new releases is available to CLECs 16, earlierversions are supported for predefined period, notification is givenbefore ILEC support is withdrawn, process is in place that prioritizesneeds for changes; (20) procedures on dealing with major software errorsor incompatibilities in a production environment are documented, methodsfor regression to prior releases are adequately documented andavailable; (21) capacity limits or metric thresholds are defined anddocumented; (22) development, testing, and production environments havedetailed procedures for adjusting maximum capacity, resources areavailable for dynamic allocation and load balancing, technicaldevelopment support has procedures and resources to handle changes indemand, ILEC documentation describes general capacity managementprocedures, a capacity management methodology is documented; and (23)back-up plans and procedures exist and are documented for emergencysystem failures related to increased transaction volume or number ofinterface users.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

C. RMI Account Establishment and Management Test

This test evaluates ILEC policies and practices for establishing andmanaging account relationships between ILEC 14 and CLECs 16. ILECaccount management teams serve as the primary points of contact for theCLECs 16 that interact with the ILEC 14. Responsibilities includeintroducing new CLECs 16 to ILEC products and services, distributingdocumentation and contact lists to CLECs 16, communicating routine andemergency notifications to CLECs 16, scheduling and leading networkplanning meetings, and interfacing with other ILEC units. The ILECprocedures for certain account management activities (e.g., returningCLEC calls) is typically set forth in the ILEC's pre-filing commitmentwith the regulatory entity. The objectives of this test are to determinethe adequacy and completeness of the ILEC's procedures for developing,publicizing, conducting, and monitoring account management.

Sources of data for this test include structured interviews with ILECSMEs, review of relevant ILEC documentation, and any other appropriatesources. In one embodiment, this test includes four broad components:(1) a procedural evaluation; (2) an evaluation of the ILEC's compliancewith its pre-filing commitments; (3) an evaluation of the management andstructure of documentation made available to the CLECs 16; and (4) aperformance evaluation concerning the ILEC's timeliness in responding toCLEC inquiries and requests.

In measuring responsiveness in connection with the performanceevaluation, the testing entity may rely on historical data obtained fromILEC 14, one or more CLECs 16, or both. As an example, ILEC accountmanagers may maintain weekly logs of incoming calls from CLECs 16 andthe timeliness of their response to those calls. In one embodiment, thetesting entity: (1) submits a formal data request to ILEC 14 for allthese call logs for a specified time period; (2) reviews the call logs;(3) separates data for calls received while account manager(s) are inthe office from data for calls received while account manager(s) are outof the office or otherwise unavailable; (4) for each set of data,determines the number and percentage of calls returned the same day, thenext business day, and later than the next business day; (5) comparesthe results with the ILEC's call return policy, as specified in itspre-filing commitment or other documentation; and (6) generates testresults accordingly. In addition, limited CLEC verification of the ILECdata may be obtained for this test. Specifically, input may be solicitedfrom CLECs 16 using written questionnaires and requests for contactnames. For the CLECs 16 that respond with contact names, the testingentity interviews the contacts regarding their interaction with ILECaccount managers and determines whether the CLEC-provided information isconsistent with the data received from ILEC 14.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures

Process Areas Sub-Process Areas Measures Criteria Establishing anStaffing Appropriate roles and 1-3, 7 account responsibilitiesrelationship Capacity, coverage, and 1-2 account allocation MaintainingEscalation Adequacy and completeness 1, 5-6 an account of escalationprocedures relationship Communications Compliance with pre-filing 9-22commitment for industry letters and conferences Adequacy andcompleteness 1, 8 of emergency communications and notificationsDocumentation - Document development and Adequacy and completeness 23-33CLEC handbook(s) distribution of CLEC handbook development anddistribution procedures Document structure Adequacy and completeness23-33 of CLEC handbook structure Maintaining Response to inquiries andTimeliness of response 34-35 an account requests for assistancerelationship

Evaluation criteria may include one or more of the following, in anysuitable combination and without limitation:

Procedural Evaluation: (1) responsibilities and activities are clearlydefined; (2) account management staff are organized to provideappropriate account coverage; (3) a complete description of the accountestablishment and management process is documented; (4) instructions forcontacting account managers are clearly defined and published; (5) theprocedures for receiving, managing, and resolving CLEC inquiries aredefined; (6) the procedures for escalating critical, time-sensitive, andunresolved customer issues are defined; (7) procedures for makingroutine communications to customers are defined; and (8) procedures formaking emergency notifications and communications to customers aredefined.

Compliance Evaluation: (9) comprehensive ILEC account management guidedescribes roles and responsibilities of the account manager; (10)account managers interact with other ILEC units on behalf of CLECs 16;(11) ILEC 14 has formal procedures for alternative account managercoverage in the event of primary account manager's absence for vacation,illness, training, or the like; (12) ILEC 14 designates and notifieseach CLEC 16 about its alternative account manager and provides voicemail greetings indicating when the alternative account manager should becontacted; (13) account manager responsibilities are posted on theILEC's website; (14) account managers are equipped with laptopcomputers, pagers, and cell phones; (15) ILEC 14 has senior managementand technical support staff to support account managers; (16) proceduresare formalized to return CLEC calls in a timely manner (e.g., on the dayreceived if the account manager is available and in no event later thannext business day); (17) performance measures (as defined in the ILECpre-filing) used to allocate account managers and evaluate whether toadd account managers; (18) the account managers sponsor and activelyparticipate in a user group for facilities-based CLECs 16; (19) ILEC 14provides notification of “quiet periods” (resulting from tandem switchsoftware upgrades or switch replacements) as they occur and at leastthirty days in advance of any such period; (20) ILEC 14 providesnotification of urgent situations impacting “quiet period” schedules assoon as ILEC 14 becomes aware of the need to modify the quiet periodschedule; (21) CLECs 16 are notified thirty days in advance of cutoverswhen CO switches are replaced; and (22) ILEC 14 provides and updates alist of COs with known physical collocation space constraints and COswith only unconditioned space remaining.

Documentation Evaluation: (23) the ILEC responsibilities and proceduresfor developing, updating, and correcting documentation are clearlydefined; (24) the responsibilities and procedures for maintainingdistribution lists and for distributing documentation are clearlydefined; (25) the distribution procedure allows the latest documentversions to be made available to interested parties in electronic andpaper format in a timely manner; (26) training is provided for use ofdocumentation; (27) the document version is indicated clearly throughouteach document; (28) document provides cross-references and has clearcitations directing readers to relevant sources of additionalinformation; (29) documents instruct users how to notify ILEC 14 aboutdocument errors or omissions; (30) documents indicate their scope andpurpose; (31) documents contain tables of contents; (32) documents arelogically organized with clear page numbering and section labeling; and(33) documents contain glossaries of terms, including explanations ofacronyms.

Performance Evaluation: (34) whether CLEC calls are returned in a timelymanner (e.g., on the same day they are received) when the accountmanager is in the office; and (35) whether CLEC calls are returned in atimely manner (e.g., no later than the following business day) when theaccount manager is out of the office or otherwise unavailable.

Considerations relevant to particular evaluation criteria may include,without limitation (consideration for a criterion being listed after thenumber of the criterion): (1) organization/team chart, responsibilitiesand roles are defined, responsibilities are documented; (2) list ofaccount managers assigned to CLECs 16, “buddy” system is utilized tobackup other account managers, documentation on account management staffis made available; (3) internal document establishing guidelines andprocedures for account managers, the process for addressing roles andresponsibilities of account managers are documented; (4) different meansof addressing questions/concerns are available, other account managercontact information available if primary account manager is absent; (5)tracking system for responding to CLEC calls, procedures for addressinginquiries documented; (6) account manager knowledgeable in resolvingissues, account manager familiar with proper resources in addressingCLEC issues; (7) process in communicating with CLEC 16 is documented,different mediums used in communicating with CLECs 16 effectively; (8)notifications to the CLECs 16 are communicated are executed in aneffective manner, emergency notifications are sent out to the properpersons; (9) roles and responsibilities of account managers aredocumented and accessible by CLECs 16; (10) account manager acts onbehalf of CLEC 16 to address any UNE concerns, account manager hasworking knowledge of UNE; (11) procedures for coverage are documentedand available to CLECs 16, contact information for backup is madeavailable to CLECs 16; (12) procedure for handling alternative accountmanagers is documented, contact list of the alternative account managersexists; (13) the responsibilities are available and documented onwebsite, accurate and current contact information; (16) call logs aremaintained in a database, process is documented, turn around onreturning calls meets documented guidelines and expectations; (17)regular performance metrics in place; process of performance evaluationis documented; (23) specific teams and roles are responsible forupdating documentation, process of reviewing, and integrating teams forshared knowledge is in place; (24) distribution list is maintained andupdated in a database, personnel are responsible for interacting withthe CLECs 16 for current information, different means (e.g., Internet,e-mail) in place for distributing documentation; (25) most recentupdates are available and current to the CLECs 16, notifications aresent out to distribution list for latest document updates; and (26)information is readily accessible and is arranged in a logical manner,electronic versions of documentation available for performing quicksearch queries.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

D. RMI NDR, Collocation, and Interconnection Planning Test

This test evaluates certain key aspects of the ILEC's network designrequest (NDR), collocation, and interconnection planning procedures.ILEC 14 is typically required to provide these services to anyfacilities-based CLECs 16 to support the provisioning of UNEs. In oneembodiment, the test includes an NDR evaluation and a collocation andinterconnection planning evaluation.

In general, the NDR process involves ILEC 14 gathering information froma CLEC 16 concerning its desired service offerings, jointly determiningwith CLEC 16 a network design suitable for establishing its presence inthe ILEC's network, and initiating the establishment of CLEC servicesbased on the CLEC's desired product offerings (e.g., determining LineClass Codes, collocation and trunking requirements, operator servicesand billing preferences, etc.).

Virtual or physical collocation may be required for any CLECs 16 wishingto offer UNE services such as local loop or interoffice facilities.Virtual collocation involves a CLEC 16 purchasing equipment that theILEC 14 then administers and maintains within its CO according to CLECinstructions. Although the equipment is dedicated to the CLEC's use,CLEC 16 will not typically have physical access to the equipment.Physical collocation involves ILEC 14 providing a secure location in itsCO for the CLEC 16 to install, maintain, and administer equipment. Thecollocation process generates a number of issues. For example, forvirtual collocation, CLEC 16 must procure and deliver the equipment in atimely manner, ILEC 14 must identify rack space for storing theequipment, CLEC 16 must have orders provisioned on the equipment todetermine that it is fully functional, and ILEC 14 must adequatelymaintain the equipment. For physical collocation, ILEC 14 must determinespace availability and the cost to prepare the space for collocation,must prepare the space for collocation, and must conduct one or moremeetings to turn the collocation cage over to CLEC 16. Although the testis described as if collocation is the manner in which CLECs 16 must gainaccess to UNEs, other appropriate ILEC products (e.g., Enhanced LocalLoop (EEL)) and interconnection for other suitable purposes (e.g.,network-to-network interconnection with a long distance carrier) may beexamined according to particular needs.

The sources of data for this test may include interviews with ILEC SMEsaccording to predetermined interview guides, review of relevant ILECdocumentation, observation of ILEC activities, and any other suitableinformation sources. The test objectives may include: (1) determiningwhether CLEC 16 has sufficient information to adequately prepare forNDR, collocation and interconnection planning activities; (2) determinewhether the NDR planning process is sufficiently well structured andmanaged to yield the desired results; (3) determine whether thecollocation planning process is sufficiently well structured and managedto yield the desired results; and (4) determine whether theinterconnection planning process is also sufficiently well structuredand managed to yield the desired results.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures Process Areas Sub Process Areas MeasuresCriteria NDR process Preparation for Usability and 8 NDR meetingscompleteness of NDR forms NDR meetings Adequacy and 1-7 completeness ofprocess Collocation Collocation require- Usability and See mentsforecasting completeness of results collocation forecast from forms TestI Evaluation of Adequacy and 9-23 collocation require- completeness ofments process process Forecast analysis Availability of results See tocommission and results CLECs from Test I Inter- InterconnectionCompleteness and 9-12, 14- connection planning information usability ofinstruc- 23 planning requirements tions for preparing for theinterconnection planning meeting Evaluation of Adequacy and 9-12, 14-Interconnection completeness of 23 Planning process process

Evaluation criteria for the NDR evaluation may include, withoutlimitation: (1) NDR responsibilities and activities are well defined;(2) scope and objectives of NDR are clearly defined and documented; (3)essential elements of NDR process are in place and adequatelydocumented; (4) the NDR process includes procedures for addressing anyerrors and exceptions; (5) the NDR process defines key meetings andmilestones; (6) processing intervals for NDR are established; (7) anescalation and problem resolution method is established; and (8) formsand templates are provided facilitating data collection for NDR.

Evaluation criteria for the collocation and interconnection planningevaluation may include, without limitation:

Procedural Consistency and Integrity: (9) collocation projects areplanned and executed according to a documented and structuredmethodology; (10) the ILEC and CLEC collocation responsibilities areclearly defined; (11) collocation methodology specifies key meetings andmilestones; (12) a common tracking system is used to track collocationprojects; (13) decisions are documented and communicated to all key ILECand CLEC participants; (14) procedures are defined to ensure that theCLECs 16 have access to facilities as required; (15) collocation processincludes a dispute resolution and escalation process; (16) proceduresare defined to ensure that qualified personnel are assigned to aproject; and (17) procedures are defined to ensure that project staffare available to collaborate and are empowered to resolve issues at theworking level.

Scope, Schedule, and Cost Management: (18) procedures are established todefine the scope of each collocation project; (19) formal procedures arefollowed to change scope and changes in scope are quantified andtracked; (20) the sequence and duration of collocation activities aredefined and documented, including establishing list of due dates fordeliverables for CLECs 16 and ILEC 14; (21) deviations from plannedschedule are tracked and managed; (22) costs of collocation activitiesare estimated and documented; and (23) procedures are in place to managethe costs of collocation activities and collocation price changes thatmay affect a CLEC 16 are communicated before they are incurred.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

E. RMI System Administration Help Desk Functional Test

This test evaluates certain key aspects of the ILEC's systemadministration help desk procedures for processing, closing, tracking,and escalating calls from CLECs 16 regarding the connectivity andadministration of their system interfaces to ILEC 14. Depending on thenature of the call, the issue may be resolved during the course of thecall, referred to another technician for communication with CLEC 16, orreferred to a more appropriate ILEC help desk (e.g., POP Domain helpdesk 50) for further processing. ILEC management practices for capacityplanning, performance measurement, and process improvements are alsoevaluated.

The sources of data for this test may include structured interviews withILEC SMEs according to interview guides, review of the relevant ILECdocumentation, observation of ILEC activities, and any other appropriateinformation sources. The test objectives may include, withoutlimitation: (1) determining the completeness and consistency of overallsystem administration help desk process; (2) determine whether theescalation procedures are correctly maintained, documented, andpublished; (3) determining the existence and functionality of proceduresfor measuring, tracking, projecting, and maintaining systemadministration help desk performance; (4) ensure existence of reasonablemeasures to ensure integrity of system administration help desk data andthe ability to restrict access to parties with specific accesspermissions; and (5) ensure the overall effort has effective managementoversight.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria Receive help Resolution of user Completeness and 1-3, 6-8, deskcall question, problem, consistency of 10-1 or issue process Close helpClosure posting Completeness and 1, 4, 8-10 desk call consistency ofprocess Status tracking Status tracking and Completeness and 1, 8-11 andreporting reporting consistency of reporting process Problem Userinitiated Completeness and 1, 4, 11 escalation escalation consistency ofprocess Capacity Capacity planning Completeness and 1, 12, 14,management process consistency of 16 process Security and Data accesscontrols Safety of process 1, 6, 13 integrity Process General manage-Completeness and 1, 10, 12, management ment practices consistency of14-16 operating manage- ment practices Performance Controllability, 1,14-15 measurement efficiency and reli- process ability of processProcess improve- Completeness of 1, 16 ment process improve- mentpractices

Evaluation criteria for this test may include one or more of thefollowing, in any suitable combination and without limitation:

Procedural Consistency and Integrity: (1) responsibilities andactivities are clearly defined; (2) scope of services includes all keyCLEC requirements; (3) the scope and objectives are clearly defined,documented, and communicated to CLECs 16; (4) a complete (i.e.beginning-to-end) description of the help desk process is documented;and (5) the help desk process includes procedures for addressing errorsand exceptions;

Procedural Elements: (6) help desk process includes complete andconsistent call intake procedures (e.g., for logging andacknowledgement); (7) the help desk process defines criteria andprocedure for severity coding of help desk calls; (8) the help deskprocess includes procedures for referral; (9) the help desk processincludes complete and consistent procedure for closure posting; (10) thehelp desk process includes complete and consistent procedures for statustracking and management reporting; (11) the help desk process includescomplete and consistent procedures for escalating issues/problems; (12)help desk process includes complete and consistent procedures forcapacity planning; and (13) help desk process includes procedures formaintaining security and integrity of data access controls.

Performance Measurement and Reporting: (14) suitable process performancemeasures are defined and measured; (15) responsibilities for trackingperformance are assigned; and (16) process improvement procedures aredefined and responsibilities assigned.

Considerations relevant to particular evaluation criteria may include,without limitation (consideration for a criterion being listed after thenumber of the criterion): (1) organization charts, job descriptions,responsibility charters, documentation exists, documentation availableto CLEC and ILEC personnel, process flows; (2) access to help desk isdefined and appropriate, customer responsibilities and customer provideddata requirements defined, ILEC actively and regularly solicits input,procedures are clear, documented, and followed; (6) call answering androuting, data logging, call-backs, the procedures are clear, documented,and followed; (7) call answering and routing, call logging datarequirements, priorities and severity codes, procedures are clear,documented, and followed; (9) time and causes are posted, criteriaestablished to close a call, procedures are clear, documented, andfollowed; (10) setting target dates, regular status reporting, statusaccess, management oversight; (11) the process includes standards forescalation, procedures are clear, documented, and followed,documentation made available to CLEC and ILEC personnel; (12) loadmeasurement, load projection, work force requirements plans, actions tochange capacity defined, criteria for action defined, responsibility forcapacity action is assigned, procedures are clear, documented, andfollowed; (13) safeguards against unauthorized access to data, dataaudits, procedures are clear, documented, and followed; (14)representative training, SME support, process flows, work instructionsand business rules, tools, logs, timeliness standards, timelinessmeasures are aligned with generally accepted standards, timeliness ofprocess is measured, the procedures are clear, documented, and followed,existence of measures, measurement processes, management reviews,management interventions; and (15) responsibility assigned, historicalperformance improvement activities, process for making changes definedand documented.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

F. RMI System Administration Help Desk Performance Test

This test evaluates the performance of the system administration helpdesk process in terms of timeliness from inception (i.e. receipt ofcall) to closure (i.e. resolution of issue). This test may relyprimarily on the analysis of performance data concerning closed troubletickets maintained in an ILEC database. Information may be obtained fromone or more CLECs 16 and used to validate such ILEC-provided data whereappropriate.

ILEC procedures typically instruct system administration help deskpersonnel to log all incoming calls in an appropriate database. In oneembodiment, each such call is assigned a unique trouble ticket number inthe database. The date the trouble ticket was opened, relevant CLECinformation, and a description of the issue and its resolution arelogged in the database. Each trouble ticket may also be assigned aseverity code (e.g., critical, major, minor, enhancement,informational). The ILEC procedures also typically require these troubletickets to be “closed” upon resolution and their closure dates to belogged in the database. The database may maintain the “age” of eachtrouble ticket, for example, the number of days the trouble ticket hasremained open.

In one embodiment, the testing entity creates a closed trouble ticketdatabase using the information in the system administration help deskdatabase, for example, by extracting the trouble ticket number, severitycode, age, and date opened from the system administration help deskdatabase for all records having a closed ticket status. To measure thetimeliness of the ILEC's closure posting process, the testing entity maythen perform the following operations, without limitation: (1) reviewthe closed trouble ticket database for records with obvious dataanomalies and exclude such records from the analysis; (2) sort therecords in the closed trouble ticket database by severity code; (3)review the records to determine the length of time between the inceptionand closure for each record (i.e. the age of the trouble ticket atclosure); (4) sort the records according to their ages at closure, forexample, in intervals of one or more days; and (5) generate test resultsreflecting the ages at closure for the trouble tickets of each severitycode. The records might be further sorted according to the dates thetrouble tickets were opened to provide information about how performancemay have changed over time.

In addition, limited CLEC verification of selected ILEC data may beused. Specifically, input may be solicited from CLECs 16 using writtenquestionnaires and requests for contact names. For the CLECs 16 thatrespond with contact names, the testing entity interviews these contactsand reviews relevant information regarding their interaction with theILEC system administration help desk. The testing entity then determineswhether the CLEC-provided information is consistent with the dataobtained from ILEC 14.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures Process Sub-Process Areas Areas MeasuresEvaluation Criteria Close Help Closure Timeliness of Specifiedpercentage of Desk Call posting process trouble tickets are closedwithin specified number of days following inception

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

G. RMI System Administration Help Desk Validation Test

This test evaluates call logging, severity coding, closure posting, andother practices of the ILEC's system administration help desk againstinternal ILEC rules and procedures such as those described above inconnection with the RMI System Administration Help Desk Functional Test.

In one embodiment, the testing entity performs the following steps,without limitation: (1) conduct one or more walk-throughs of the systemadministration help desk to observe ILEC activities and discussprocedures with ILEC SMEs; (2) review appropriate ILEC documentation;(3) review suitable information contained in the system administrationhelp desk database; and (4) analyze a subset of information in thesystem administration help desk database (e.g., all trouble ticketrecords opened during a selected time period) to spot-check evaluationsof one or more measures, for example, severity coding accuracy and calllogging completeness. The information analyzed should preferably providea representative sample to increase the reliability of the test results.Where CLEC participation is available, it may be desirable to validatethe accuracy of the responses provided to CLECs 16 and the accuracy ofclosure postings.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures Process Sub-Process Areas Areas MeasuresCriteria Initiate help User interface Ease or use or user interface 1desk call processing Process help Call logging Accuracy and completenessof 2 desk call call logging Severity coding Accuracy and completeness of3 severity coding

Evaluation criteria for this test may include one or more of thefollowing, in any suitable combination and without limitation: (1) thehelp desk interface is clearly and logically organized; (2) call loggingprocedures are complete; and (3) calls are completely and accuratelyseverity coded in compliance with the ILEC's documented procedures.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

H. RMI CLEC Training Test

This test evaluates certain aspects of the ILEC's CLEC training programto determine the existence and operation of its procedures fordeveloping, publicizing, conducting, managing, and monitoring CLECtraining. A CLEC training program will typically offer training coursesconcerning various ILEC products and services available to CLECs 16.Training opportunities, along with specific dates, times, and locationsof training sessions, may be publicized through various media. CLECs 16are preferably able to request on-site and customized training from ILEC14. The ILEC's CLEC training function may be responsible for holdingclasses, developing courses and curricula, monitoring instructors, andevaluating training effectiveness, among other suitable activities.

Sources of data for this test may include structured interviews withILEC SMEs according to interview guides, review of the relevant ILECdocumentation and databases, observation of ILEC activities, and anyother suitable information sources. The test objectives may include,without limitation: (1) determining the existence and functionality ofprocedures for developing, publicizing, conducting, and monitoring CLECtraining; and (2) ensuring that the ILEC's CLEC training effort haseffective management oversight.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures Process Sub-Process Areas Areas MeasuresCriteria Training Develop Completeness of training 1-3, 7, 9 programcurriculum curriculum and forums development Adequacy of procedures to1, 4-6, 8- respond to information about 9, 11-12 training quality andutilization Adequacy of procedures to 1, 6, 8-9, accept CLEC inputregarding 12 training curriculum Publicize Availability of information1, 10 training about training opportunities opportunities TrainingAttendance/ Adequacy of process to track 1, 3, 8, program utilizationutilization and attendance of 11, 14 quality tracking various trainingtools and assurance forums Session Adequacy of process to survey 1, 3,8-9, effectiveness training recipients on 12 tracking effectiveness oftraining Instructor Adequacy of procedures to 1, 3, 5-6, oversightmonitor instructor 9, 12-13 performance Process PerformanceControllability, efficiency and 1, 5-6, 8, management measurementreliability of process 12 process Process Completeness of process 1, 4,8, improvement improvement practices 12-14

Evaluation criteria for this test may include one or more of thefollowing, in any suitable combination and without limitation, withoutlimitation:

Procedural Consistency and Integrity: (1) training processresponsibilities and activities are clearly defined; (2) the scope andobjectives of the training process are clearly defined and documented;(3) essential elements of the process are in place and adequatelydocumented; and (4) the process includes procedures for addressingerrors and exceptions.

Procedural Elements: (5) the scope of training services covers all keyCLEC requirements; (6) process includes adequate procedure forresponding to feedback about training quality and utilization; (7)process includes adequate procedures for accepting CLEC input regardingtraining curriculum; (8) process includes procedures for publishinginformation about CLEC training opportunities; (9) process includesprocedures to track utilization and attendance of training tools andforums; (10) the process includes procedures to survey trainingrecipients on training effectiveness; (11) process includes proceduresto monitor instructor performance; and (12) training offerings arescalable in response to additional demand (e.g., increased class sizeand number of instructors).

Performance Measurement and Reporting: (13) training process performancemeasures are defined and measured; and (14) responsibilities fortracking training-related performance are assigned.

Considerations relevant to particular evaluation criteria may include,without limitation (consideration for a criterion being listed after thenumber of the criterion): (1) organizational structure exists, processis documented, roles and responsibilities are defined; (2) trainingprocess is documented and available to instructors, objectives ofcourses are defined and training session covers all defined objectives;(3) course descriptions, availability of courses, feedback mechanisms asto course material and instructor; (4) the responsibilities are clearlydefined for addressing errors, feedback mechanisms for notifying errors,communicating updated documentation to CLECs 16; (5) customized classesmade available, training/support is made available after trainingsessions; (6) feedback mechanisms on course material and instructorexist, significant means of tracking feedback from trainees, databasecontains up to date surveys per course and instructor; (7) CLEC feedbackis conveyed through proper channels, different media are available forfeedback; (8) course offerings are readily accessible, scheduling ofcourses is capable of meeting enrollment demands; (9) the tracking ofattendance exists, database contains relevant data for trackingattendance, database capable of identifying attendance based on specificcriteria; (10) procedures are in place to allow trainees to comment oncurriculum, surveys are distributed to trainees for feedback; (11)process provides feedback to instructor on a regular basis, there arealternative methods of approaching and preparing course material torefine instructor performance, evaluations of course materials andinstructor provided by management and trainees, knowledge and teachingmethodologies of instructors are considered in evaluations; (12)sufficient coverage exists for demand of instructors and meeting classrequirements, course offerings are arranged in a logical sequence withpre-requisite requirements; (13) specific performance metrics used tomonitor progression of instructors and the course curriculum; and (14)performance tracking methodologies and responsibilities are in place.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

I. RMI Forecasting Validation Test

This test evaluates the ILEC's CLEC forecasting process to determine theexistence and functionality of procedures for developing, publicizing,conducting, and monitoring forecasting efforts and for ensuring that theoverall forecasting effort has effective management oversight. ILEC 14will typically use its CLEC forecasting process to obtain informationfrom relevant CLECs 16 regarding historical, current, forecasted, orother local demand to allow ILEC 14 to better anticipate future needs.ILEC 14 may review CLEC information to develop its own marketingassumptions, product assumptions, and demand forecasts to allow ILEC 14to properly size and locate network resources, anticipate capacityrequirements for its OSSs 12 and other operational elements, and thelike.

Sources of data for this test may include structured interviews withILEC SMEs according to interview guides, review of the relevant ILECdocumentation and databases, observation of ILEC activities, and anyother suitable information sources. The test objectives may include,without limitation: (1) determining the existence and functionality ofprocedures for developing, publicizing, conducting, and monitoringforecasting efforts; and (2) ensuring that the overall forecastingeffort has effective management oversight.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how evaluationcriteria may, in one embodiment, correspond to particular evaluationmeasures.

Test Target Areas and Measures Process Areas Sub-Process Areas MeasuresCriteria Fore- Forecast development Compliance with documented 1-5, 8casting ILEC forecasting procedures Forecast publication Availability ofpublished 5-9 and confirmation forecast summaries

Evaluation criteria for this test may include one or more of thefollowing, in any suitable combination and without limitation:

Procedural Consistency and Integrity: (1) forecasting processresponsibilities and activities are clearly defined; (2) scope andobjectives of the process are clearly defined; (3) essential elements ofthe process are in place and adequately documented; and (4) the processincludes procedures for addressing errors and exceptions; and

Procedural Elements: (5) forms and templates are provided to facilitatedata collection from CLECs 16; (6) the data provided by each CLEC 16 isconfirmed and verified; (7) ILEC summaries of forecasts are distributedto the CLECs 16; (8) the process includes requirements for periodicforecast revisions; and (9) procedures are in place to preserve theconfidentiality of proprietary CLEC information.

Considerations relevant to particular evaluation criteria may include,without limitation (consideration for a criterion being listed after thenumber of the criterion): (1) responsibilities for processingforecasting, CLEC responsibilities for submitting information; roles andresponsibilities of ILEC personnel, organizational charts; (2)documentation check, ILEC interview; (3) process review, documentationcheck, ILEC interview, account manager responsibilities; (4)documentation check, ILEC interview, account manager responsibilities;(5) website check, any industry updates, account managerresponsibilities; (6) documentation check for the procedures, ILECinterview, account manager responsibilities, process verification forCLEC data; (7) confidentiality issues associated with CLEC-specificmarket information of ILEC, ILEC interview; (8) internal improvements,workshops, any industry updates; and (9) ILEC code of conductinformation, roles and responsibilities of ILEC personnel in thisregard, ILEC interview.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

Cross-Domain Evaluation

In one embodiment, the testing entity may perform a live, end-to-endcross-domain evaluation to represent the real CLEC experience ratherthan by proxy using test bed accounts as for many of the tests describedabove. For example, this cross-domain evaluation may focus on businessdigital, residential analog, or other lines. The objective of the testis to evaluate the ILEC's POP, M&R, and Billing Domain systems in realworld conditions. The testing entity may use the results of this test asa control by comparing it to information obtained from domain-specifictesting. This may allow the testing entity to validate the results ofits domain-specific testing and therefore provide an important technicaladvantage. An example process for cross-domain testing is illustrated inFIG. 17, where “TE” refers to the testing entity and associatedpersonnel.

For the POP activities, the testing entity may place pre-orders andorders for new lines and migrations at actual business and residentlocations. Order interfaces including EDI, GUI, and manual, may beemployed to submit these service requests to ILEC 14. Commonly requestedline types and features will preferably be ordered, possibly involvingnumerous scenarios. Pre-orders will be evaluated for timeliness,accuracy, and completion. The testing entity will evaluate ordering andprovisioning of lines by verifying the timeliness and accuracy of eachinstallation or migration. Volume performance, documentation, help desksupport, capacity management, and perhaps other POP Domain activitiesfall outside of the scope of this test and are preferably tested usingspecific POP Domain tests described above.

For the M&R activities, physical damage may be intentionally generatedon selected lines to initiate the M&R process. This should allow thetesting entity to assess the M&R process on the customer end. Thetesting entity may evaluate the M&R function based on response time,time the trouble is resolved, and accuracy of trouble resolution.MRTAS-related processing and performance, documentation, help desksupport, and perhaps other M&R Domain activities fall outside the scopeof this test and are preferably tested using specific M&R Domain testsdescribed above.

For the billing activities, the testing entity should evaluate theaccuracy and completeness of the bills attributed to each line based onthe line type and features provisioned by installing various types oflines having a variety of features. The testing entity may developunique usage scripts for each line in order to test billing activities.Usage scripts may be developed with predetermined call destinations,call times, and call durations to ensure the accuracy of billingassessment. The billing activities preferably cover approximately twocomplete billing cycles, although this may be adjusted according toparticular needs. Billing metrics, documentation, and cycle fall outsidethe scope of this test and are preferably tested using specific BillingDomain tests described above.

For business lines, for example, the testing entity may requestapproximately ten individual lines of varying types and features to beinstalled (all under separate business accounts). Selected new linesthat will be added as a result of this test may be migrated. Uponconnection or subsequent migration, the lines will be verified to assesswhether the type of line and the features ordered were in factprovisioned in a timely manner. After installation, testers will make anumber of calls (e.g., over two billing cycles) following predeterminedusage scripts. These business lines will be used solely for the purposesof the Cross-Domain Evaluation. Bills will be evaluated to determinethat the correct fees and pricing have been applied based on the type ofline and features ordered and provisioned. Accuracy and completeness ofthe bills based on usage are also evaluated. At various points duringthe test, selected lines may be intentionally damaged. Test testingentity will report the service problem to initiate the ILEC's M&Rprocess; document the ILEC response time, resolution time, and accuracyof problem resolution; and again test the line for functionality. Allbusiness lines will be disconnected after the usage scripts have beencompleted and M&R tests have been performed. The testing entity willreview the final business bills to determine that correct fees andpricing have been applied based on the type of line and features.

Performance Metrics Review

In general, the Performance Metrics Review involves a series of tests tobe undertaken in evaluating the systems, processes, and otheroperational elements that are associated with the ILEC's support forperformance metrics. The testing entity preferably performs these testsin addition to domain-specific metrics tests described more fully above.The report generated by the testing entity should allow the regulatoryentity to assess the net impact of any metrics-related problems that itidentifies on the ability of CLECs 16 to operate in an open competitiveenvironment in the state or other jurisdiction of interest.

In one embodiment, the Performance Metrics Review may be broken downinto a number of test target areas which collectively encompass, withoutlimitation, standards and definitions, data processing, and dataretention. Each of these target areas may be further broken down intoincreasingly discrete process and sub-process areas that identifyparticular areas to be tested and types of measures that apply to eacharea. According to the present invention, one or more tests aredeveloped to evaluate each test target area based on the scope oftesting to be performed in each area. There may not be a one-to-onecorrespondence between test target areas and specific tests designed toevaluate test target areas. In a particular embodiment, the PerformanceMetrics Review tests may include: (1) a Data Collection and StorageTest, (2) a Metrics Definition Documentation and Implementation Test,(3) a Metrics Change Management Test, (4) a Metrics Data Integrity Test,(5) a Metrics Calculation and Reporting Test, and (6) a StatisticalEvaluation of Transactions Test. Example embodiments of these tests aredescribed below.

A. Data Collection and Storage Test

This test evaluates key policies and practices for collecting andstoring raw and target data necessary for the creation of performancemetrics. Both procedures for data used in the calculation of thereported metrics and for data required in the calculation of retailanalogs are included. The test may rely primarily on interviews,document reviews, and inspections. The objectives of this test are todetermine the adequacy and completeness of key ILEC policies andprocedures for collecting and storing performance data.

Entrance criteria for the test may include all global entrance criteriahaving been satisfied, an appropriate test-specific interview guide orquestionnaire having been developed, interviewees having been identifiedand scheduled, and a detailed evaluation checklist having beencompleted. Test activities may include, without limitation: (1) collectappropriate information; (2) review the collection and storage policiesand procedures for both CLEC data and data used in calculations ofretail analogs; (3) perform walkthrough inspection of ILEC facilitiesthat are relevant to production of performance measurements; (4) performinterviews and documentation reviews; (5) complete evaluation checklistand interview summaries; and (6) develop and document findings. Exitcriteria may be limited to global exit criteria.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how particularevaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Sub Process Areas Areas MeasuresCriteria Collection Collection policies Adequacy and 1-3 of data andprocedures for completeness of CLEC and retail collection policies dataand procedures Identified collection Applicability of and  4 pointsmeasurability from control points Collection tools Adequacy andscalability 5-6 of data collection tools Internal controls Adequacy and7-8 completeness of the internal control process Storage Storagepolicies and Adequacy and  9-11 data procedures for completeness ofstorage CLEC and retail policies and procedures data Identified storageApplicability of and 12 sites measurability from control points Storagetools Adequacy and scalability 13-14 of data storage tools Internalcontrols Adequacy and 15-16 completeness of the internal control process

Evaluation criteria for these measures may include, in any combinationand without limitation: (1) roles and responsibilities of datacollectors are clearly defined and documented; (2) policies andprocedures for data collection are clearly defined and documented; (3)technical guides describing the data collected are available; (4) theILEC 14 is able to identify the exact points of data collection; (5)ILEC 14 has adequate capacity to collect data; (6) ILEC 14 has a clearlydefined plan for future capacity to collect data; (7) the ILEC 14 hasclearly defined and documented error checking mechanisms for collectionof data; (8) the ILEC 14 has an adequate and documented security processto collect data; (9) roles and responsibilities of data storagepersonnel are clearly defined and documented; (10) policies andprocedures for data storage are clearly defined and documented; (11)technical guides describing data storage are available; (12) ILEC 14 isable to identify the exact points for data storage; (13) ILEC 14 hasadequate capacity to store data; (14) ILEC 14 has a clearly defined planfor future capacity to store data; (15) ILEC 14 has clearly defined anddocumented error checking mechanisms for storing data; and (16) ILEC 14has an adequate and documented security process for data storage.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

B. Metrics Definition Documentation and Implementation Test

This test evaluates the overall policies and practices for documentingand implementing metrics definitions. This may include policies andpractices associated with both CLEC and retail measurements. The testmay rely primarily on interviews and document reviews. The objectivesare to determine the adequacy, completeness, accuracy, and logic ofperformance metrics documentation. Implementation of the definitions inthis test may cover both the exclusions and business rules applied increating the raw data and any exclusions and business rules applied incalculating metrics from raw data. In one embodiment, this goes beyonddetermining whether metrics as produced by ILEC 14 are consistent withthe documented definitions, as described above in connection with thePOP Metrics Test for example.

Entrance criteria for the test may include all global entrance criteriahaving been satisfied, an appropriate test-specific interview guide orquestionnaire having been developed, interviewees having been identifiedand scheduled, and a detailed evaluation checklist having beencompleted. Test activities may include, without limitation: (1) collectall appropriate information; (2) perform interviews and reviewdocumentation; (3) evaluate the adequacy and appropriateness of themeasures set forth in the ILEC's metrics documentation; (4) complete theevaluation checklist and interview summaries; and (5) develop anddocument findings in report. Exit criteria may be limited to global exitcriteria.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how particularevaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Areas Sub Process Areas MeasuresCriteria Metrics Documentation of Adequacy and complete- 1-2, 5definition metrics definitions ness of metrics definitions Documentationof Accuracy and logic of 3 calculation of the documented metricscalculation of metrics Implementation of Consistency between 4exclusions and business documented exclusions rules in creating raw andbusiness rules, and data and calculating exclusions and businessmetrics. rules used Validity of instructions Consistency between 6-7 forcalculation of metrics documented definitions and documentedinstructions for calculation

Evaluation criteria for these measures may include, in any combinationand without limitation: (1) the process to develop and document metricsdefinitions is complete and consistent; (2) the metrics definitions areconsistent with the intent of metrics as reflected in their titles; (3)documented metrics calculations are consistent with documented metricsdefinitions; (4) all the documented metrics exclusions are appropriate;(5) metrics definitions are made available in accordance with requireddistribution guidelines; (6) the process to develop and document metricsstandards is complete and consistent; and (7) metrics standards are madeavailable in accordance with required distribution guidelines.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

C. Metrics Change Management Test

This test evaluates the ILEC's overall policies and practices formanaging changes in its production and reporting of metrics. The changesof concern relate to the management of, and communication to CLECs 16and the regulatory entity of, appropriate metrics definitions andstandards, information systems, reports, raw data, documentation, andany related processes. The policies and practices involved may relate toboth CLEC measurements and, where the standards are retail analogs,retail measurements. This test may rely primarily on interviews anddocument reviews. The objectives of this test are to determine theadequacy and completeness of key ILEC procedures for developing,implementing, monitoring, and publicizing changes concerning performancemetrics.

Entrance criteria for the test may include all global entrance criteriahaving been satisfied, an appropriate test-specific interview guide orquestionnaire having been developed, interviewees having been identifiedand scheduled, and a detailed evaluation checklist having beencompleted. Test activities may include, without limitation: (1) collectall appropriate information; (2) perform interviews and reviewdocumentation; (3) evaluate the ILEC's change management practicesrelating to metrics; (4) complete evaluation checklist and interviewsummaries; and (5) develop and document findings. Exit criteria may belimited to global exit criteria.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how particularevaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Areas Sub Process Areas MeasuresCriteria Change Developing change Completeness and consistency 1 manage-proposals of change development ment process Evaluating changeCompleteness and consistency 2 proposals of change evaluation processImplementing Completeness and consistency 3 change of changeimplementation process Intervals Reasonableness of change 4 intervalDocumentation Timeliness of documentation 5-6 updates Tracking changeAdequacy and completeness 7 proposals of change management trackingprocess

Evaluation criteria for these measures may include, in any combinationand without limitation: (1) ILEC 14 has a complete and consistentprocess for developing metrics change proposals; (2) the ILEC 14 has acomplete and consistent process for evaluating metrics change proposals;(3) the ILEC 14 has a complete and consistent process for implementingmetrics change proposals; (4) the interval for developing, evaluating,and implementing metrics changes is reasonable; (5) ILEC 14 updates itsdocumentation in a timely and complete manner; (6) ILEC 14 has anadequate and complete notification process about metrics changes anderrors; and (7) ILEC 14 has an adequate and complete process fortracking metrics changes.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

D. Metrics Data Integrity Test

This test evaluates the overall policies and practices for processingthe data used by ILEC 14 in producing reported performance metrics andstandards. This test may rely primarily on document reviews,inspections, and comparison of samples of data from different stages ofprocessing. Historical CLEC-aggregate and retail data are the subjectsof the test. The objective of this test is to determine the integrity ofthe key ILEC procedures for processing the data necessary to produceperformance metrics.

Entrance criteria for the test may include all global entrance criteriahaving been satisfied, an appropriate test-specific interview guide orquestionnaire having been developed, interviewees having been identifiedand scheduled, and a detailed evaluation checklist having beencompleted. Test activities may include, without limitation: (1) collectappropriate documentation; (2) perform interviews and reviewdocumentation; (3) complete the evaluation checklist and interviewsummaries; (4) gather data samples; (5) analyze data; (6) evaluate theILEC data processing policies and practices relating to metrics; and (7)develop and document findings in report. Exit criteria may be limited toglobal exit criteria.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how particularevaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Areas Sub Process Areas MeasuresCriteria Data Transfer of data from Adequacy and complete- 1 integritypoint(s) of collection, ness of the data transfer with emphasis onprocess inappropriate deletions Conversion of data from Adequacy andcomplete- 2 unprocessed to processed ness of the conversion form withemphasis on policies and procedures distortions Data transfer policiesand Adequacy and complete- 3 procedures for CLEC and ness of datatransfer retail data policies and procedures Internal controls Adequacyand complete- 4 ness of the internal control process

Evaluation criteria for these measures may include, in any combinationand without limitation: (1) ILEC's transfer of unprocessed records toprocessed records is complete; (2) the ILEC 14 did not add inappropriaterecords to processed data; (3) unprocessed data was transformedaccurately to processed data; and (4) ILEC 14 has a complete andconsistent internal control process to ensure that data is transferredand transformed properly.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

E. Metrics Calculation and Reporting Test

This test evaluates the processes used to calculate performance metricsand retail analogs. The test will rely on re-calculating CLEC-aggregatemetrics and retail analogs from historical raw data and reconcilingdiscrepancies to verify and validate the reporting of the metrics. Thetest may rely primarily on document reviews and inspections. Theobjectives of the test are to determine the accuracy of recent (or otherhistorical) metrics calculations and reports.

Entrance criteria for the test may include all global entrance criteriahaving been satisfied, having access to the ILEC's target database asverified by the Data Collection and Storage Test described above, ILECdefinitions and standards having been verified by the Metrics Definitionand Documentation Test described above, an appropriate test-specificinterview guide or questionnaire having been developed, the intervieweeshaving been identified and scheduled, and a detailed checklist havingbeen completed. Entrance criteria may also include successful completionof the Metrics Change Management Test described above. The testactivities may include, without limitation: (1) collect all appropriatedocumentation; (2) perform interviews and review the documentation; (3)complete the evaluation checklist and interview summaries; (4) gatherthe historical data; (5) recreate performance metrics based on targetdata; (6) evaluate ILEC metrics calculations; and (7) develop anddocument findings in report. Exit criteria may be limited to global exitcriteria.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how particularevaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Areas Sub Process Areas MeasuresCriteria Metrics Replication of Agreement between re- 1-2 calculationmetrics calculated and reported calculations metrics valuesReconciliation of Reconciliation of re- 3 discrepancies calculated andreported metric values Implementation of Consistency between 4-5instructions for documentation calculation calculation of metrics andcalculation performed

Evaluation criteria for these measures may include, in any combinationand without limitation: (1) ILEC-reported and re-calculated metricsvalues agree; (2) the ILEC provided data to calculate metrics values isadequate and complete; (3) ILEC carrier-to-carrier metrics reports areaccurate and complete; (4) ILEC implemented metrics calculations areconsistent with the documented calculations; and (5) ILEC implementedmetrics exclusions are consistent with documented exclusions.

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

F. Statistical Evaluation of Transactions Test

This test evaluates the ILEC's service performance for the pseudo-CLEC18 using statistical techniques to make comparisons to parity andbenchmark standards. The test will rely on statistical methods deemedappropriate by the testing entity, ILEC 14, and other interestedparties. Comparisons are preferably not conducted for performancemeasures for which a retail analog or benchmark is not established. Inone embodiment, the test compares ILEC performance metrics generated forpseudo-CLEC 18 with metrics for the ILEC's retail analogs or withanother predetermined standard.

Entrance criteria for the test may include all global entrance criteriahaving been satisfied, having access to the ILEC's target database asverified by the Data Collection and Storage Test described above, ILECdefinitions and standards having been verified by the Metrics Definitionand Documentation Test described above, an appropriate test-specificinterview guide or questionnaire having been developed, the intervieweeshaving been identified and scheduled, and a detailed checklist havingbeen completed. Entrance criterion may also include successfulcompletion of the Metrics Calculation and Reporting Test describedabove. The test activities may include, without limitation: (1) collectall the appropriate documentation; (2) perform documentation review; (3)complete evaluation checklist; (4) gather appropriate data; (5)calculate statistics based on performance metrics; and (6) develop anddocument findings in report. Exit criteria may be limited to global exitcriteria.

Test target areas and associated evaluation measures are summarized inthe table below. The last column of the table indicates how particularevaluation criteria may, in one embodiment, correspond to particularevaluation measures.

Test Target Areas and Measures Process Areas Sub Process Areas MeasuresCriteria Statistical Calculate and compare Test statistic exceedsQuantitative evaluation test statistic to critical critical value value,depending on metric

Based on evaluation checklists or otherwise, test results may begenerated (“Satisfied,” “Not Satisfied,” etc.) and comments provided foreach of the evaluation criteria used in the particular instance of thetest.

Although the present invention has been described with severalembodiments, a plethora of changes, substitutions, variations,alterations, and modifications may be suggested to one skilled in theart, and it is intended that the invention encompass all such changes,substitutions, variations, alterations, and modifications as fall withinthe spirit and scope of the appended claims. Furthermore, the presentinvention is not intended to be limited in all embodiments to acomprehensive testing methodology that spans multiple domains, multipletests within a particular domain, or multiple process areas, sub-processareas, evaluation measures, evaluation criteria, or other elementswithin a particular test. Those skilled in the art will readilyappreciate that any chosen element or combination of elements taken fromthe above description is sufficient to define a distinct invention. Forexample, even a particular consideration relevant to a particularevaluation criteria for a particular test may comprise a distinctinvention for which patent protection may be sought and obtained,subject only to the teachings of the prior art. That said, it isanticipated that many distinct inventions described above may involvemultiple elements, for example, multiple test domains, multiple testswithin one or more domains, multiple process areas, sub-process areas,evaluation measures, evaluation criteria, considerations, or otherelements for one or more tests. Moreover, it is anticipated thatApplicants will select various aspects of their inventions to claim atvarious time over the life of this application and other applicationsbased on this application. Those skilled in the art will appreciate thata decision not to claim a certain aspect at a certain time does not inany way preclude that aspect from being claimed at a later time.

APPENDIX A Example Test Scenarios Scenario Description 1 Migration “asis” of BA-NY small business customer to CLEC UNE platform. 2 Migration“as is” of BA-NY residential customer to CLEC UNE platform. 3 PartialMigration of BA-NY residential customer's line to CLEC resale/UNEPlatform. 4 A new small business customer orders service from a CLECwith dispatch required. 5 A new residential customer orders service froma CLEC with dispatch required. 6 Migration with change of a BA-NY smallbusiness customer to CLEC UNE Platform. 7 A CLEC's existing smallbusiness customer moves. 8 Add a feature to CLEC's small businesscustomer. 9 Disconnection of CLEC small business customer migrating backto Bell Atlantic. 10 Migrate CLEC resale small business customer to CLECUNE Platform. 11 Change PIC. 12 Small business adds 3 lines to existing3 line hunt group with due date change. 13 Disconnection of CLEC smallbusiness customer. 14 Add features to CLEC's residential customer. 15Migration “as is” of BA-NY small business customer's ISDN line andbusiness line to CLEC. 16 Migration “as specified” of BA-NY residentialcustomer to CLEC UNE Platform. 17 Migration “as specified” of BA-NYsmall of business customer to UNE Platform. 18 Migration “as specified”of BA-NY small business customer's ISDN line(s) to CLEC UNE Platform. 19Migration “as is” of BA-NY medium business customer's digital Centrex toCLEC. 20 Add line with features to Scenario 19 customer. 21 Second orderfor Scenario 19 customer -- Five of 11 lines in hunt group. 22 Anexisting CLEC residential customer moves. 23 Order for a residentialline with a directory listings. 24 Order for a residential line with adirectory listing with an existing telephone number. 25 Seasonalsuspension/restoration of service for a CLEC residential customer. 26Change telephone number of a CLEC residential customer. 27 Changedirectory listing of a CLEC's residential customer. 28 Resale of an ISDNbasic line to CLEC's residential customer. 29 Move of residence servicewithin the same building. 30 Change CLEC residential customer's linefrom POTS to ISDN. 31 Migration “as specified” of BA-NY residentialcustomer to CLEC residential POTS with an unlisted number. 32 Addhunting to CLEC's small business customer line. 33 Migration “as is” ofBA-NY residential customer to CLEC residential POTS with unlistednumber. 34 Migration “as is” of BA-NY residential customer to CLECresidential POTS with unlisted number. 35 Migration “as is” of areseller residential customer to a CLEC. 36 Migration “as is” of BA-NYsmall business customer to resale. 37 Migration with changes of BA-NYsmall business customer to resale. 38 Migration “as specified” of BA-NYsmall business customer's lines with a change to hunt groups. 39Migration of CLEC large business customer with a DS1 Special Accesscircuit to UNE Loop and UNE IOF. 40 Migration “as is” of a BA-NY largebusiness customer with a DS1/DS3 circuit and 3/1 Multiplexor to UNE Loopand UNE IOF. 41 Convert four BA-NY DS1s to UNE loops cross-connected toCLEC CoLo 42 Migration “as is” of 50 BA-NY Centrex stations for CLECCentrex resale. 43 Migration 20 out of 8 BA-NY Centrex stations for CLECCentrex resale. 44 Add pick-up group to existing re-sold Centrex. 45Migration “as is” of 10 business lines. 46 A small business moves 4resale lines across the street. 47 23 Special Access DS1s with 3/1 MUXto DS3 converted to UNE Loop and UNE IOF. 48 16 Special Access DS1sconverted to UNE Loop and UNE IOF. 49 DS1 UNE loop MUXed to DS3 UNE IOF.50 DS1 UNE loop MUXed to DS3 and cross connected to CoLo. 51 DS1 loopcross-connected to CoLo, MUXed to DS3, cross-connected in BA-NY SWC toDS3. 52 DS1 trunk from CLEC CO to BA-NY Access Tandem. 53 DS3 UNE IOFfrom CLEC to BA-NY SWC. 54 Migrate “as is” 10 DID, 10 DOD, 4 two-way PBXtrunks. 55 Add 10 new DOD trunks to support telemarketing campaign toScenario 54 customer. 56 Arrange 20 DID trunks into 2 pick-up groups. 57Convert 75 PBX trunks to UNE loops, cross connect at CLEC CoLo forconnection to CLEC Centrex. 58 Migrate “as is” 4 ISDN lines. 59 Convertresale/platform lines to unbundled loops. 60 Convert 8 ILEC ISDN linesto 2-wire digital loops for cross connection to CLEC CoLo ADSL modems.61 A CLEC has a re-sold Centrex Customer, and buys 3-way calling to beadded to 40 stations. 62 A CLEC buys 8 existing DS1s for transfer andconnection to CLEC CoLo as UNE 4W digital loops. 63 A CLEC buys 20 newCentrex stations connected to the customer via the CLEC CoLo and CLECfacility. 64 Centrex customer orders a new caption listing. 65 Custom800 with 2 lines serving each of 10 locations. 66 Customer changescomplex caption listing. 67 Convert 4 existing special access DS3sconnecting customer's premise with two CLEC Central Offices to UNE Loopsand UNE IOF. 68 A CLEC orders access from CLEC Central Office to ILECLIDB. 69 A CLEC orders interconnection from 5 CLEC Central Offices toILEC “Custom 800” SCP. 70 A portion of a customer's existing BA-NYservice is converted to a CLEC using EEL. 71 A CLEC orders a CoLomini-cage. 72 A CLEC orders a virtual CoLo. 73 CLEC orders dedicated DS1trunk port with dedicated DS1 IOF ordered as a new UNE combination. 74 ACLEC orders 10 new DS1s for interconnection trunks from ILEC CO to CLECCO. 75 A CLEC customer buys 20 existing line ports for cross-connectionto CLEC facility at CLEC CoLo. 76 Obtain Customer Service Records (CSR).77 Base Scenario 77: TN Inquiry. 78 Base Scenario 78: TNReservation/Release. 79 Feature Availability Inquiry. 80 Due DateSelection 81 Address Validation 82 DID Number Block Availability 83 DIDTrunk Inquiry 84 Available PIC Inquiry 85 A business customer's newservice is provided by the CLEC using EEL. 86 Resale POTS customercannot originate or receive calls on CLEC line. 87 Small Business POTSUNE-P customer cannot receive or originate calls. 88 Business customerreports failure of one of four 4-wire DS1 UNE digital loops. 89Residential POTS UNE-P customer can no longer use Repeat Dialing. 90 Alarge business customer reports outage on DS1 UNE loop MUXed to DS3 UNEIOF. 91 CLEC busy six new 4-wire digital DS1 UNE loops for amedium-sized ISP in NYC. 92 A CLEC buys 25 new 2-wire analog loops for abranch of a national company. 93 Small business customer migrates toCLEC, served by CLEC switch and 4 UNE loops, keeps 4 TNs. 94 Smallbusiness customer migrates to CLEC, served by CLEC switch and 4 UNEloops, keeps 4 TNs. 95 Small business customer converts from InterimNumber Portability to Long Term Number Portability. 96 Residentialcustomer migrates to CLEC, served by CLEC switch and 2 UNE loops, keeps2 TNs. 97 Residential customer migrates to CLEC, served by CLEC switchand 2 UNE loops, keeps 2 TNs. 98 Residential customer converts fromInterim Number Portability to Long Term Number Portability. 99 CLECResale customer finds that call waiting no longer works. 100 Small CLECbusiness customer, served by CLEC switch and 4 UNE loops can not receivecalls after migration from ILEC to CLEC with LNP. 101 Small businesscustomer served by CLEC via UNE Loops, with LNP, can originate calls butcannot receive calls. 102 Small business customer disconnects part oftheir UNE loops. 103 Customer with 2 lines requests a telephone numberchange on the auxiliary line. 104 Customer with 2 lines requests atelephone number on the BA-NY BTN. 105 Customer with a resold linechanges their class-of-service. 106 Business customer reports failure ofone of four 4-wire DS1 UNE digital loops. 107 CLEC customer disconnectstheir Centrex service. 108 Resale POTS customer reports noisy line andcross-talk to CLEC. 109 Small business customer now on CLEC UNE Platformreports NDT on one of his three lines. 110 Pick-up group order onexisting re-sold Centrex did not process correctly. Customer reportsproblem to CLEC. 111 Customer with 4 ISDN lines reports he is unable tosend packet data over the “D” channel lines. 112 CLEC issues a requestfor Trouble History on all four lines for a small business customer. 113CLEC residential customer reports NDT on both of his lines. 114 CLECISDN Customer served by a Bell Atlantic line port reports that callscannot be originated on his second line. 115 Business customer reportshigh bit-error-rates on one of three 4-wire DS0 UNE premium loops. 116CLEC purchases and resells digital private line services to one of itsexisting small business customers. 117 CLEC adds lines to an existingcustomer. 118 CLEC customer disconnects some of its POTS lines. 119Existing CLEC customer adds POTS lines. 120 CLEC customer disconnectsall ISDN BRI lines. 121 CLEC customer moves its ISDN BRI line. 122 CLECcustomer adds an ISDN BRI line. 123 Migration “as is” of BA-NY customerISDN PRI lines to CLEC. 124 CLEC customer disconnects an ISDN PRI line.125 CLEC customer adds a new leg to multi-point circuit. 126 CLECcustomer disconnects a private line circuit. 127 Migration of BA-NYcustomer's POTS service to CLEC UNE loops without NP. 128 CLEC customermoves UNE - analog loop. 129 CLEC customer addes new digital loops. 130Migrate customer to CLEC using EEL. 131 CLEC customer to disconnectservice provided in EEL. 132 Medium CLEC ISP customer disconnects 2 of 84-wire digital DS1 UNE loops. 133 CLEC customer experiences trouble onone of his private lines provided in part by an ILEC 4-wire DSO digitalloop.

Example Flow Through Test Cases Scenario for Case Description 27 Changeresidual listing from unlisted to listed. 27 Change business listingfrom unlisted to listed. 27 Change residential listing from unpublishedto listed (UNE-p) 27 Change business listing from unpublished to listed27 Change residential listing from listed to unlisted/unpublished(UNE-p) 27 Change business listing from listed to unlisted/unpublished(UNE-p) 70 A portion of a customer's existing BA-NY service is convertedto a CLEC 16 using EEL. UNE 85 A business customer's new service isprovided by the CLEC 16 using EEL. 85 A business customer's new serviceis provided by the CLEC 16 using EEL. 85 CLEC 16 provisions residentialcustomer with at least two lines via EEL. 92 CLEC 16 buys 25 new 2 wireanalog loops for a new customer to the area. (With DL) 92 CLEC 16 buys 1new 2-wire analog loop for a new residence customer to the area. (WithDL) 92 CLEC 16 buys 112-wire analog loops for new business customer tothe area. (With DL) 92 CLEC 16 buys additional 1 loops for existingbusiness CLEC 16 customer (With DL) 92 CLEC 16 buys 1 additional loopfor existing residence CLEC 16 customer (With DL) 94 Small businesscustomer migrates to CLEC 16. Customer is served by the CLEC 16 switchand 4 UNE loops. The TNs are ported using INP LINE (With change to DL)94 Same as above except customer ports 2 TNs, not all 4. (With change toDL) 96 Residential customer migrates 1 line to CLEC 16 and isprovisioned off of CLEC 16 switch. Customer pons the 1 TN to the CLEC 16switch. CLEC 16 ports via LNP (long term # portability). LINE 97Residential customer migrates to CLEC 16. CLEC 16 purchases 2 UNE loops.Customer retains TNs through interim # portability. (With DL) 102 Smallbusiness customer disconnects his UNE loop. UNE 102 Residence customerserved by CLEC 16 via UNE loop(s) disconnects her service. 102 Businesscustomer w/UNE digital loop disconnects part of her service. 117 CLEC 16adds lines to an existing customer using EEL UNE 127 BA-NY customermigrates 1 line to CLEC 16. CLEC 16 purchases 1 UNE loop from BA.Customer changes to CLEC 16 TN. Business Customer. (With DL) 127 BA-NYcustomer migrates 1 line to CLEC 16. CLEC 16 purchases 1 UNE loope fromBA. Customer changes to CLEC 16 TN. Residence customer. (With DL) 127 BAcustomer migrates 1 of 5 existing lines to CLEC 16. CLEC 16 purchases 1UNE loop from BA. Customer changes to CLEC 16 TN. Business Customer.(With DL) 130 Migrate residential customers to CLEC 16 using EEL withoutnumber portability. UNE 130 Migrate business customs to CLEC 16 usingEEL without number portability. UNE 131 CLEC 16 customer to disconnectservice provided via EEL. 2-line residential customers. UNE 131 CLEC 16customer to disconnect service provided via EEL. 2-line residentialcustomers. UNE

What is claimed is:
 1. A method for testing one or more operationalsupport systems (OSSs) of an incumbent provider for compliance with aregulatory scheme, the method performed by an independent testing entityattempting to emulate a competitive provider that would access the OSSsin attempting to compete with the incumbent provider in an opencompetitive market, the method comprising: conducting active testing ofthe OSSs with respect to one or more variables; evaluating performanceof the incumbent provider during active testing with respect to the oneor more variables according to predetermined evaluation criteriacomprising one or more performance metrics, evaluation of incumbentprovider performance comprising: for performance metrics requiring theincumbent provider to meet a particular performance standard, using aone-sample t-test for continuous variable performance metrics and abinomial test for discrete variable performance metrics; and forperformance metrics requiring parity between incumbent providerperformance for operations of the incumbent provider associated with itsinteraction with competitive providers and incumbent providerperformance for its internal operations, using a two-sample t-test forcontinuous variable performance metrics and a hyper-geometric test fordiscrete variable performance metrics; generating test results accordingto the evaluation; and issuing a final report comprising the testresults and providing a sufficient basis for a regulatory entityadministering the regulatory scheme to determine compliance of theincumbent provider with the regulatory scheme.
 2. The method of claim 1,wherein the testing is performed to allow the regulatory entity toconsider whether and to what extent the incumbent provider providescompetitive providers non-discriminatory access to, use of, and supportin connection with the OSSs relative to that available to the incumbentprovider in its internal operations.
 3. The method of claim 1, wherein:the incumbent provider comprises an incumbent local exchange carrier(ILEC); the competitive providers comprise competitive local exchangecarriers (CLECs); the regulatory entity is associated with a Statewithin the United States of America; and the regulatory scheme comprisesSection 271 of The Telecommunications Act of 1996, codified in the lawsof the United States of America at 47 U.S.C. §§151 et seq.
 4. The methodof claim 1, wherein: a continuous variable performance metric comprisestime; and a discrete variable performance metric comprises whether anevent occurred.
 5. The method of claim 1, wherein: incumbent provideroperations associated with its interaction with competitive providerscomprise retail operations; and internal incumbent provider operationscomprise wholesale operations.
 6. The method of claim 1, wherein forcontinuous variable performance metrics where the sample size isrelatively small according to a predetermined scale, evaluation ofincumbent provider performance further comprises using a permutationtest.
 7. The method of claim 1, wherein the test results comprise ap-value representing a significance level.
 8. A method for testing oneor more operational support systems (OSSs) of an incumbent provider forcompliance with a regulatory scheme, the testing being associated withmetrics capture, tracking, and reporting activities of the incumbentprovider with respect to a particular operational domain, the methodbeing performed by an independent testing entity attempting to emulate acompetitive provider that would access the OSSs in attempting to competewith the incumbent provider in an open competitive market, the methodcomprising for testing of an OSS: within a data integrity testingcomponent during active testing, to determine whether filtered data theincumbent provider uses to calculate values for each of one or moremetrics is accurately derived from raw data the incumbent providercollects in connection with transactions associated with the OSS:identifying one or more fields in the filtered data that the incumbentprovider uses in calculating values for the metric; identifying a randomsample of transactions associated with the OSS; obtaining from theincumbent provider copies of records associated with the identifiedtransactions, the records containing raw data for these transactionsfrom which filtered data for these transactions in the identified fieldswas derived; and for each identified field, determining whether thefiltered data for the identified transactions in the identified field isconsistent with the raw data for the identified transactions containedin the associated records; within a metrics replication testingcomponent during active testing, for each of one or more metrics forwhich the incumbent provider has calculated values: obtaining from theincumbent provider a description of the metric, filtered data on whichthe incumbent provider based its calculation of values for the metric,and an algorithm according to which the incumbent provider made itscalculation of values for the metric, the filtered data being associatedwith a specified time period, the filtered data being derived from rawdata the incumbent provider collected in connection with transactionsassociated with the OSS; re-calculating values for the metric accordingto the description, data, and algorithm obtained from the incumbentprovider; and determining whether the re-calculated values areconsistent with the values calculated by the incumbent provider;evaluating performance of the incumbent provider during active testingaccording to predetermined evaluation criteria; generating test resultsaccording to the evaluation; and issuing a final report comprising thetest results and providing a sufficient basis for a regulatory entityadministering the regulatory scheme to determine compliance of theincumbent provider with the regulatory scheme.
 9. The method of claim 8,wherein the testing is performed to allow the regulatory entity toconsider whether and to what extent the incumbent provider providescompetitive providers non-discriminatory access to, use of, and supportin connection with the OSSs relative to that available to the incumbentprovider in its internal operations.
 10. The method of claim 8, wherein:the incumbent provider comprises an incumbent local exchange carrier(ILEC); the competitive providers comprise competitive local exchangecarriers (CLECs); the regulatory entity is associated with a Statewithin the United States of America; and the regulatory scheme comprisesSection 271 of The Telecommunications Act of 1996, codified in the lawsof the United States of America at 47 U.S.C. §§151 et seq.
 11. Themethod of claim 8, wherein the regulatory entity requires the incumbentprovider to calculate values for the metrics and report calculatedvalues for the metrics to the regulatory entity for oversight purposes.12. The method of claim 8, wherein: the operational domain comprises apre-ordering, ordering, and provisioning domain; the OSS is associatedwith pre-ordering, ordering, and provisioning activities of theincumbent provider; and the transactions comprise orders for localtelecommunications services.
 13. The method of claim 12, wherein theorders comprise Local Service Requests (LSRs).
 14. The method of claim8, wherein the identified fields are those the incumbent provider usesrelatively often in calculating values for the metric.
 15. The method ofclaim 8, wherein identifying the records within the data integritytesting component comprises: requesting the incumbent provider toprovide a location of the records; and requesting the incumbent providerto identify one or more incumbent provider personnel to explain therecords, determination of which identified records to inspect beingbased at least in part on interaction with the identified incumbentprovider personnel.
 16. The method of claim 8, further comprising withinthe data integrity testing component, requesting the incumbent providerto research and explain any discrepancies between the filtered data andcorresponding raw data before evaluating the performance of theincumbent provider with respect to the data integrity testing component.17. The method of claim 8, wherein: the operational domain comprises apre-ordering, ordering, and provisioning domain; the OSS is associatedwith pre-ordering, ordering, and provisioning activities of theincumbent provider; the transactions comprise orders for localtelecommunications services; and the method further comprises trackingprogress of orders during a test period encompassing the active testingand activities of the testing entity occurring before the activetesting, the testing entity requesting from the incumbent provider rawdata for orders submitted to the OSS during an initial portion of thetest period and filtered data generated for provisioned and pendingorders during substantially all of the test period, the testing entitycomparing filtered data for provisioned and pending orders with raw datafor corresponding submitted orders to determine whether the filtereddata is consistent with the raw data.
 18. The method of claim 8, furthercomprising developing one or more software components to implement theobtained algorithms at a computer system of the testing entity.
 19. Themethod of claim 8, further comprising within a statistical analysistesting component during active testing: accessing correctly calculatedvalues for one or more metrics associated with internal operations ofthe incumbent provider and correctly calculated values for these metricsassociated with operations of the incumbent provider involvingcompetitive providers; interacting with one or more incumbent providerpersonnel to determine how data on which the correctly calculated valuesare based is collected and processed at the incumbent provider toconfirm that this data can be expected to allow for correct inferencesbased on comparisons of correctly calculated values; statisticallycomparing the correctly calculated values for internal operations withthe correctly calculated values for operations involving competitiveproviders; and according to the statistical comparison, drawing one ormore inferences as to parity between the correctly calculated values forinternal operations and the correctly calculated values for operationsinvolving competitive providers.
 20. The method of claim 19, wherein thecorrectly calculated values are calculated using data collected duringan active testing period under conditions that are statistically similarto conditions outside of the active testing period.
 21. The method ofclaim 19, wherein the correctly calculated values are calculated by thetesting entity rather than the incumbent provider.
 22. The method ofclaim 19, wherein: the internal operations comprise wholesaleoperations; and the operations involving competitive providers compriseretail operations.
 23. The method of claim 19, further comprisingaccounting for differences in one or more of geography, transactionsize, and transaction type between the correctly calculated values forinternal operations and the correctly calculated values for operationsinvolving competitive providers in drawing one or more inferences as toparity.
 24. The method of claim 8, wherein the operational domaincomprises a maintenance and repair domain, the OSS is associated withmaintenance and repair activities of the incumbent provider, and thetransactions comprise trouble reports associated with localtelecommunications services.
 25. The method of claim 8, furthercomprising in a surveillance testing component during active testing:observing incumbent provider activities within the operational domain;reviewing incumbent provider documentation within the operationaldomain; interviewing incumbent provider personnel identified as beingfamiliar with the operational domain; generating a process mapassociated with the operational domain according to the observing,reviewing, and interviewing; submitting the process map to the incumbentprovider for confirmation that the process map is accurate; uponconfirmation that the process map is accurate, using the process map toidentify any differences between a process of the incumbent providerused for its wholesale operations within the operational domain and aprocess of the incumbent provider used for its retail operations withinthe operational domain; and evaluating process parity between thewholesale and retail operations of the incumbent provider according toany identified differences.
 26. A method for testing one or moreoperational support systems (OSSs) of an incumbent provider forcompliance with a regulatory scheme, the testing being associated withperformance metrics capture, tracking, and reporting activities of theincumbent provider across a plurality of operational domains, the methodperformed by an independent testing entity attempting to emulate acompetitive provider that would access the OSSs in attempting to competewith the incumbent provider in an open competitive market, the methodcomprising: conducting a metrics data collection and storage test duringactive testing to evaluate incumbent provider policies and practices forcollecting and storing data used for calculating performance metricvalues, both for internal operations of the incumbent provider and foroperations of the incumbent provider associated with its interactionwith competitive providers; conducting a metrics definitiondocumentation and implementation test during active testing to evaluateincumbent provider policies and practices for documenting andimplementing performance metric definitions, implementation ofperformance metrics definitions comprising applying exclusions andbusiness rules in calculating performance metric values based on rawdata; conducting a metrics change management test during active testingto evaluate incumbent provider policies and practices for developing,implementing, monitoring, and reporting changes concerning performancemetrics; conducting a metrics data integrity test during active testingto evaluate incumbent provider policies and practices for processingdata necessary to calculate performance metric values; conducting ametrics calculation and reporting test during active testing to evaluatepolicies and practices of the incumbent provider for calculatingperformance metric values, this test comprising: accessing calculatedperformance metric values for operations of the incumbent providerassociated with its interaction with competitive providers, these valueshaving been calculated by the incumbent provider and thereafter reportedto the regulatory entity; re-calculating the accessed performance metricvalues; comparing the re-calculated values with the accessed values toidentify any discrepancies; attempting to reconcile any identifieddiscrepancies between the re-calculated values and the accessed values;and determining whether the incumbent provider calculated the accessedvalues consistent with documented instructions for doing so; conductinga statistical evaluation of transactions test during active testing toevaluate metrics-related service performance of the incumbent provideraccording to statistical techniques, this test comprising: accessingtest performance metric values calculated based on interaction betweenthe incumbent provider and the testing entity; accessing benchmarkperformance metric values calculated based on interaction between theincumbent provider and one or more competitive providers; and comparingthe test performance metric values with the benchmark performance metricvalues according to statistical techniques to determine whether and towhat extent parity exists between the compared values; evaluatingperformance of the incumbent provider during active testing according topredetermined evaluation criteria; generating test results according tothe evaluation; and issuing a final report comprising the test resultsand providing a sufficient basis for a regulatory entity administeringthe regulatory scheme to determine a net impact of identifiedmetrics-related issues on the ability of competitive providers tocompete with the incumbent provider in an open competitive market. 27.The method of claim 26, wherein the testing is performed to allow theregulatory entity to consider whether and to what extent the incumbentprovider provides competitive providers non-discriminatory access to,use of, and support in connection with the OSSs relative to thatavailable to the incumbent provider in its internal operations.
 28. Themethod of claim 26, wherein: the incumbent provider comprises anincumbent local exchange carrier (ILEC); the competitive providerscomprise competitive local exchange carriers (CLECs); the regulatoryentity is associated with a State within the United States of America;and the regulatory scheme comprises Section 271 of TheTelecommunications Act of 1996, codified in the laws of the UnitedStates of America at 47 U.S.C. §§151 et seq.
 29. The method of claim 26,wherein the regulatory entity requires the incumbent provider tocalculate values for metrics and report calculated values for metrics tothe regulatory entity for oversight purposes.
 30. The method of claim26, wherein the operational domains comprise one or more of: apre-ordering, ordering, and provisioning domain, one or more OSSs beingassociated with pre-ordering, ordering, and provisioning activities ofthe incumbent provider; a maintenance and repair domain, one or moreOSSs being associated with maintenance and repair activities of theincumbent provider; a billing domain, one or more OSSs being associatedwith billing activities of the incumbent provider; and a relationshipmanagement and infrastructure domain, one or more OSSs being associatedwith relationship management and infrastructure activities of theincumbent provider.
 31. The method of claim 26, wherein the testing isconducted in addition to domain-specific metrics testing in one or moreof the operational domains.
 32. The method of claim 26, wherein:internal operations of the incumbent provider comprises wholesaleoperations; and operations of the incumbent provider associated with itsinteraction with competitive providers comprise retail operations.